Certified anti-money-laundering specialist Christine Duhaime looks at anti-money-laundering measures in i-gaming and the importance of effective AML compliance programmes.
THE gambling sector, whether it be online or land-based, is one of the most heavily regulated and controlled in the world, both from a gambling and an anti-money-laundering perspective.
Having a comprehensive compliance programme in place particularly for anti-money laundering, is not only a legal requirement in most jurisdictions but good business practice.
An AML compliance programme operates as a prudent mechanism to oversee and monitor timely compliance with regulatory obligations. It also helps ensure that employees at all levels are aware of the unique obligations imposed on a gambling operator and helps ensure those obligations are complied with as a matter of course throughout the operations of the company and at all levels of the organisation.
An AML compliance programme also ensures that a gambling company has an ethical and compliant culture, minimising risk to it and its directors and officers from criminal, civil and financial liability. And if problems do arise, the existence of such a programme mitigates against harsher sanctions and in some jurisdictions, may operate to strengthen a due diligence defence.
There are unique challenges presented with AML compliance programmes in the online gambling context because of the conflicts in laws arising from compliance with many jurisdictions in which the services are rendered and by virtue of the fact that all of the business is virtual and international.
Moreover, there is a broad diversity among countries in AML law, for example, in respect of who constitutes a politically exposed person, know-your-customer requirements, what constitutes a suspicious transaction and record-keeping requirements. In addition, there is no harmonisation on the reporting process to financial intelligence units.
Read the full article in the latest issue of iNTERGAMINGi.
