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By their very nature, casinos deal with large volumes of money, rendering them uniquely vulnerable to abuse by those seeking to launder ill-gotten gains.

Like all financial institutions, casinos have always been required to monitor and detect suspicious activity and file the appropriate reports with the Financial Crimes Enforcement Network FinCEN.

Last year, several prominent casinos faced stiff penalties and were required to strengthen their risk management and anti-money laundering AML procedures for reporting suspicious activity.

This year, the trend is expected to continue. Just as important, casinos need to put in place well-trained compliance staff members to constantly monitor and mitigate the risks associated with money laundering.

Regulators will expect nothing less. If not already in place, casinos should also design and implement an AML risk assessment.

It is important to perform the risk assessment annually or in conjunction with material changes in the business. At a minimum, the risk assessment methodology needs to include five key action items: A review of existing technology should also be a major focus for compliance and risk management teams.

Historically, systems utilized by the gaming industry to detect suspicious behavior have not been held to the same rigorous standards as in the banking industry.

Investments may be required and additional data may need to be captured to ensure that a casino is properly monitoring and detecting suspicious activity.

Risk scenarios and parameters need to be constantly evaluated and tested to ensure that the appropriate thresholds are in place for the risks identified by the risk assessment process.

Once an appropriate program is in place, it is just as critical to implement an independent testing function to ensure that the controls are working as designed.

There are many different approaches recognised in the development of MLRAs using qualitative and quantitative data; analysing root cause or embarking on risk journeys; asking why again and again; or using a fishbone styled approach to tease out the key issues.

They all have their value. Individual MLRAs are always prepared in a particular context. This is summarised in the first section, before consideration of the nature of the risks and finally, the controls intended to mitigate them.

Perhaps the greatest challenge is simply knowing where to start in developing a MLRA. There are, however, resources available that can help.

In October last year HM Treasury published the first national risk assessment of money laundering and terrorist financing.

This contains sections focused on online and land based casinos and the betting sector, helpfully identifying key threats together with some of the steps being taken by the industry to mitigate them.

The US has similarly developed a national risk assessment with a chapter devoted to casinos. The GB Gambling Commission can help here as well.

The detail contained in the case studies provides opportunity to learn from the experience of others — both in terms of the risks encountered, and the nature of the controls required and at times absent to mitigate them.

Resources are available then to assist a firm in developing an MLRA. The assessment is prepared in the context of these external drivers but also, vitally, in light of a number of internal factors.

The unique operating model, customer base, marketing channels and product portfolio demand an approach to developing the MLRA that is tailored to these particular characteristics.

Whilst it may be attractive to develop a MLRA that can be used by all operators within, for instance, a particular sector, this one-size fits all approach makes no consideration for the unique nature of each business and is unlikely to accurately reflect the particular risks encountered, and the required controls to mitigate them.

The identification and evaluation of money laundering risks is at the heart of any MLRA. There are many ways of doing this, and some are mentioned above.

Whatever approach is taken, it is likely to involve at least four key areas: Risks associated with the type of customers with whom an operator has potential to do business can fall into a number of areas such as:.

All gambling products have the potential to be exploited by money launderers, but some have more potential than others.

For instance, peer to peer gambling, where the parties are known to each other, presents particular risks.

Products that allow a customer to bet against all possible outcomes of an event can be misused, and fixed odds betting terminals and other electronic forms of payment have the potential to be loaded before cashing out — a recognised form of money laundering.

Understanding the nature and vulnerabilities of individual products is vital. Individuals can potentially gamble online from anywhere in the world including some jurisdictions that entail particular risks of money laundering or terrorist financing.

Some customers at land based operators may be linked to parts of the world that again give rise to particular concerns.

The means by which gambling transactions are paid for is increasingly diverse, reflecting the proliferation in the different means of payment that are increasingly available.

The use of prepaid cards, online payment systems such as Skrill and Neteller compliment more traditional forms of payment such as debit cards.

The use of cash continues to dominate much of the industry — presenting particular vulnerabilities to laundering.

Whilst it is necessary to identify and address key areas such as customer, product, geography and means of payment separately for the purpose of building a MLRA, the practical threat of money laundering will most likely entail a combination of the factors — for instance a particular type of customer using a certain product, and paying with cash.

Controls such as customer due diligence CDD , staff training and suspicion reporting are of course mandated for some operators - regardless of the level and nature of any risks presented.

A clear understanding and recognition of the laundering risks the business is exposed to will ensure that these controls are focused on, and calibrated to the right issues.

Some businesses focus their controls on limiting either the impact or the likelihood of laundering taking place - or both.

The former would entail for instance, introducing restrictions to play, or limiting the number of transactions in certain circumstances.

On the other hand controls aimed at reducing the likelihood of laundering may include customer screening, seeking consent for certain transactions and staff training.

Another way of framing controls considers the necessary steps to identify possible laundering, together with actions required when concerns are detected.

The research and analysis required to develop an effective MLRA is significant. Introducing or updating required controls can be expensive and time consuming.

The cost of failure, however, can far exceed even this — whether through legal or regulatory sanction, reputational loss or ethical failure.

Instead, it needs to be updated in light of operational and industry developments and refreshed, normally on an annual basis.

There are resources available to do this, and some are mentioned above. Perhaps most vitally, each business needs to have appropriately trained staff to develop and implement the MLRA, at a senior level to provide oversight, and at the front line to deliver against it.

Anti money laundering and risk assessment in the gambling industry by: I wrote in June about an increased regulatory focus on AML within the gambling industry.

Approach There are many different approaches recognised in the development of MLRAs using qualitative and quantitative data; analysing root cause or embarking on risk journeys; asking why again and again; or using a fishbone styled approach to tease out the key issues.

Risks associated with the type of customers with whom an operator has potential to do business can fall into a number of areas such as: By irene on Skills and attributes of a compliance officer By irene on Non-compliance not worth the gamble for casinos.

Dawn Fisher 10 tips for using LinkedIn to land your next compliance role Five minutes with the faculty: Andy Clarke July Five minutes with the faculty: Tim Tyler 6 alternative study methods Culture, ethics and….

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