I would like to thank you for spending time to answer our questions. First I would kindly ask you to shortly introduce yourself.
I am the current head of AML at one of the UK’s top Mayfair casinos as well as a trainer for the global leader in AML/social responsibility training for gambling operators (AML Gaming Solutions). I have worked for the past 7 years for the National Crime Agency as a financial investigator and within the AML expert witness team as well as within covert operations where I portrayed many roles within counter terrorism, drugs. The most relevant to my current career is that I portrayed the role of an international money launderer.
Would you please speak about the effects of AMLD 4 on the gambling industry in geneneral and in the UK in particular?
My opinion is that in general the 4th MLD has had little impact for some operators but major impact for many others (if they have made the appropriate changes). The main impact came from the requirement to “know your customers” better which for many land based operators it is not a huge change, as many of them already go a long way to know about their clientele. For many online operators this was a tough change as my opinion is that many operators do the bare minimum when it comes to due diligence. Overall, I think that many operators do not even have measures in place to comply with law from 2002 (proceeds of crime act 2002), so I would not expect those operators to be doing anything to comply with law that has been in place less than 10 months. The reason I say this is because many of the MLRO’s (money laundering reporting officer) or AML managers I speak with know very little about money laundering/financial crime or their roles and responsibilities and the relevant laws and regulations.
You advise large number of organisations with regards to their AML compliance programmes. According to your experience what are the most frequent problems, issues regarding this topic?
Lack of knowledge is number 1. I am not just referring to the lower level employees but with MLRO’s and AML managers, the level of knowledge sometimes scares me. I have met with MLRO’s who did not know how to input a SAR (Suspicious activity report), some did not know basic money laundering techniques and how to identify them… then these MLRO’s are entrusted to protect the business and oversee staff training, so it is effectively the blind leading the blind. I speak with some businesses who tell me that they are low risk for money laundering or that criminals do not use their business…. When I tell them that I myself have actually laundered money through their business or have spent criminal proceeds through their business they have a sudden change in attitude, which for me is a good thing. Many gambling employees have not been given the basic knowledge for preventing financial crime which is the fault of the operator. I enjoy giving staff this knowledge and empowering them to detect criminality and prevent those criminals using their businesses.
What social responsibilities does preventing money laundering include?
In many cases, social responsibility and AML go hand in hand. If an operator has good AML processes in place they will often detect problem gambling concerns and vice versa. We have seen in the recent enforcement action that when an operator is punished for their lapses in social responsibility they are also punished for their lapses in AML, this is because operators generally do not do enough to protect their customers. If an operator has done enough to determine a customer’s Source of Wealth (SOW) they should know when that customer is spending more than they can afford. Therefore if that customer is spending outside of their known income, an operator should be doing extra checks to determine if the customer is spending more, because they either have a gambling problem or they are spending more because they also have some illegitimate funds that have not previously been uncovered.
There are new regulations in this domain. Will you please speak about these and their effects?
Operators are expected to do more, and rightly so. The expectation from the regulator is that both remote and non-remote operators need to step up and start protecting customers. But this is difficult and causes a huge conflict of interest amongst operators; on one hand they are trying to run a profitable business, keep customers gambling and spending money, on the other hand they are expected to stop customer if they gamble too long or spend too much money. The punishment for not protecting customers is too soft in my opinion. The gambling commission should be taking licences and giving hefty fines, at the moment operators get away with doing very little to protect customers. Operators would do a lot more if they genuinely felt their licence was on the line or that they would be fined excessively. If we take the banking industry as an example, it took HSBC getting fined £250m for all the banks to start carrying out adequate AML due diligence, before the HSB fine banks always done the minimum because they knew any fine they received would be worth paying. I think the gambling commission is definitely moving in the right direction but they need to send out a clear message, the way to do that is to start making examples of operators.
What about the UK? Where is it heading with the new regulations?
I think the gambling commission is going to get tougher and tougher on operators until the operators eventually start looking after their customers. UK operators need to do more, especially online. There is a poor knowledge of AML and even worse knowledge on problem gambling when it comes to online operators. Staff needs to be given proper training so they can protect the businesses and their legitimate customers. I think more regulation will keep coming and will keep getting harder until operators take it upon themselves to start protecting customers.
What do you think what is gaming considered by the people of the UK today; are they satisfied with the new changes?
Public trust in gambling has drastically decreased; this is because of all the negative media on problem gambling and money laundering. I think the public are happy that the industry is under such scrutiny because financial crime and problem gambling effects so many people. Operators have the power to regain trust from the public and I do think all the changes the commission and the government are trying to make will help to regain public trust once again.
What would you change in the present state of the British gambling market?
I would make it a requirement for operators and all staff to undertake adequate and relevant training on both AML and problem gambling. Many operators put staff through poor internal courses or e-learning programs which is not good enough. AML Gaming Solutions (AMLGS) are made up of AML experts who have worked for law enforcement, government and regulators. They deliver face to face training to all staff from the ground all the way up to the CEO which is highly important. Every operator should be undertaking training from experts such as AMLGS. It is vital for staff to hear from professionals and to understand what a vital role their play in preventing financial crime and protecting customers
What is your personal opinion about gambling industry in general in Europe?
I think that the industry is moving in the right direction, the constant updates in law and regulation are a good thing and operators need to embrace the changes. I do believe that from compliance perspective more needs to be done by operators, but we are getting there slowly. The industry is going to continue to grow; it is this growth that has brought the attention of various governments and law enforcements. Five years ago the industry was not on anyone’s radar but now every government in the world has taken an interest. This scrutiny has brought a well-deserved pressure to operators who have for many years failed to prevent financial crime; I think the message is clear: step up and do more or be on the receiving end of some very harsh penalties.
Alex will join Pieter Remmers(Assissa), Martin Arendts (ARENDTS ANWÄLTE) and Dan Iliovici (National Office of Gambling Romania) in the panel discussion which is scheduled between 16:45 – 17:30 and has the following title: “Responsible Gambling, AML and Gambling Licensing Procedures in the European Union”
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