According to the regulator, the failures might be triggered by a preference for profit over safety. The causes of these flaws are almost as troubling as the flaws themselves. The case studies show that operators either do not provide adequate resources or simply prioritize economic aims over regulatory ones. This really is wholly inexcusable, and many others in the sector who strive to accomplish compliance will see it as such. According to the research, a lack of investigative work was a major contributory cause to any breaches in AML and CFT in specific. It included having insufficient due diligence mechanisms in place to start with, failing to perform due diligence in situations where it should have been applied, and relying too heavily on 3rd parties to do due diligence assessments. Furthermore, most operators’ criteria were just too high and were centered on single metrics instead of a more holistic approach.
Several operators have also been found to have “inadequate risk assessment methodology” for money-laundering & terrorism financing, as well as neglecting to evaluate how problem gambling might be related to money laundering & terrorist funding.
The Commission highlighted a lot of instances in the previous year involving inadequate checks, notably when it penalized Casumo £6 million in March after a user was permitted to lose £1.1 million without engaging in responsible gaming.
Several examples were cited as case studies to demonstrate how AML practices were also being neglected. These include a client placing £20,000 in cash on 2 separate occasions while giving false proof of identity, a customer trying to display sealed cash parcels at one casino while falsely claiming that they came from another operator, and a member of a criminal organization utilizing money obtained from crime in a famous casino.
The report also raised worry that operators were much more concerned with how failures to meet the social responsibility rules would be seen in the press when their major priority should’ve been minimizing money laundering and terrorism financing risks in the first place.
The report advised licensees that they must completely meet the terms of their license “as relevant to anti-money laundering (AML) and counter-terrorist financing (CTF).” Casino licensees must also follow the provisions of the Terror Financing, Money Laundering, and Transfer of Funds regulations 2017, as amended by the state in 2020 and 2021.
The Commission continues to find instances of operators neglecting to conduct risk assessment reviews that take into consideration the Commission’s emerging risk reports. Inadequate due diligence measures continue to be observed, increasing the risk of collecting illegal funds.