A panel of speakers in a Cybercrime, Security and Regulatory Compliance session at ICE 2016 have expressed concern about the revised customer verification and enhanced due diligence (DD) as part of the 4th Anti-Money Laundering Directive.
The European Union 4th Anti-Money Laundering Directive was officially published in June 2015 as a review on the 2007 regulations, covering all gambling services. The Directive triggered a two year process during which member states need to incorporate new requirements into domestic law.
HM Treasury lead for the UK and will set new Money Laundering Regulations (MLR) in the autumn of 2016 with the aim that these come into force in June 2017. The two year period provides opportunity for the gambling industry to plan for requirements of the MLR, and for operators to consider revised provisions within their strategic and operational planning.
From 2017, customers will be continually monitored so that their risk profiles can be updated as necessary. Enhanced DD should follow the risk-based principle, with the consequence that where a customer’s risk increases, so too should the level of DD performed on him or her.
Trevor De Giorgio, Head of International Legal Compliance at Greentube, said that the industry must refrain from making this process too cumbersome, and strike a balance between an unrealistic level of checks and the operational reality. If DD is taken too far, customers may make the move to unregulated markets in other jurisdictions.
Full Session Panel:
- Tim Tyler (Gambling Commission, Senior Manager, AML Lead)
- Mehnaz Ahmed (EU Anti-Money Laundering HM Treasury, Policy Advisor)
- Dr Jason Lane (Gaming Regulators European Forum Chairman, Jersey Gambling Commission Chief Executive)
- Neil Lambert (William Hill, Group Money Laundering Reporting Officer)
- William Price (Ladbrokes, Head of AML and Counter Terrorism Financing)
- Trevor De Giorgio (Greentube, Head of International Legal Compliance)