GAMLG is currently engaged in 4 workstreams, led by industry compliance professionals. These 4 pieces of work provide the essential ground work, on our journey to provide the industry sector codes for Anti-Money Laundering.
GAMLG has commissioned a team of industry experts to look at the developing technologies within our gambling sectors and determine the implications for higher risks or benefits to maintain our strong controls for AML.
A sample of our objectives are:
Develop a plan/proposal for technology improvements within the Retail environment that would improve the AML provision
Develop a plan/proposal for technology improvements within the Online environment that would improve the AML provision (e.g. the development of capturing up to date customer details to comply with requirement of maintaining up to date records on customers).
Develop a plan/proposal that outlines where development in technology can assist GAMLG members in improving the profiling of customers as well as the analysis of that profile .
In order to be effective in delivering an industry code, it is imperative that organisations share customer information, so that if a customer fails the industry requirements for entry for one operator, it is reciprocated across all participating operators.
The Information Commissioner has indicated that the Gambling Commission will need to ‘sign-off’ the use of customer details in this way.
GAMLG are working with the Information Commissioner, law firms and the Gambling Commission to discuss the hurdles which must be overcome, to establish legal information sharing between operators.
Our good practice guidelines for the gambling sectors that we represent, have the structure of an AML overview, with sector good practice contained within sub-sections of the main document.
In our document, GAMLG provide the overview in terms of purpose, regulatory context, senior management responsibility, working with supervisory authorities, and definitions of money laundering and terrorist financing.
The ABB and RGA have added (similar to the financial industry) their sector specific guidance that cover, for instance, internal control processes, risk based approach, SARs, data protection, the role of MRLO, employees, record keeping, customer verification and due diligence. We intend to publish this document in February 2018.
It is universally recognised that training is vital to ensure that industries, companies individuals are abreast of legal and regulatory requirements and this is very much the case in the gambling industry. Legislation in the UK governs AML in the industry coupled with the Gambling Commission various publications, notably ‘the Duties and Responsibilities under the Proceeds of Crime Act 2002, Advice to operators (excluding casino operators, (Fourth edition)
GAMLG has commissioned a project to develop an Anti-Money Laundering & Counter Terrorist Financing (AML) training model which can be utilised by all sections of the gambling community.
Objectives for the project:
Develop guidance with regards to AML training to be delivered at different target audiences:
Board members and Executives
MLRO / Nominated Officers and their deputies
Colleagues employed in the business specifically dealing with AML and CTF
Colleagues with customer interactive roles
Colleagues across the business, not directly involved with customers (eg support colleagues)
In developing AML training, use the training as a tool to cause a change in the ‘culture’ of the recipients
Develop a minimum standards of training, which can be adopted to meet individual needs and/or role holders (with different degrees of complexity.
Anti-Money Laundering Good Practice Guidelines for Licensed Betting Offices and Remote Gambling
AML Training Project
Information Sharing and Information Commissioner