• Physical Gambling

    Physical gambling is attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Physical Gambling

What are the ML/TF Risks?

Physical gambling, such as pokie machines and on-course bookmakers are attractive to criminals wanting to launder the proceeds of crime.

Bookmakers and betting agencies may also have become more attractive to criminals over the past few years as the financial sector has implemented comprehensive AML/CFT measures.

Bookmakers and betting agencies are vulnerable to money laundering activities for various reason, such as ease of access, anonymity, high volume of cash transaction.

The Money Laundering and Terrorist Financing (ML/TF) risks associated with bookmakers and betting agencies include:

  • Winnings or unused funds paid back to an account other than the one through which the original bet was made;
  • Significant volumes of cash transactions, and the need for quick processing of payments;
  • Depositing illicit cash into a betting account. Funds are later withdrawn as ‘winnings’ linking the money to a legitimate source; and
  • The avoidance of direct involvement in the money laundering process, through the use of people unrelated to the initial criminal activity.  These are known as ‘front people, mules and clean skins’ through whom betting transactions are channelled.

Bookmakers and betting agencies must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for the physical gambling, bookmakers and betting agencies industry.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

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