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This briefing note is only intended as a general statement of the law and no action should be taken in reliance on it without specific legal advice.

UK Update: Anti-Money Laundering
 Briefing 
Date
18 December 2015

UK Update: Anti-Money Laundering

On 15 December the Gambling Commission published a document detailing weaknesses identified in the Anti-Money Laundering (AML) controls in two UK land-based casinos operated by Caesars Entertainment (the Playboy and the Casino at the Empire).

The key criticisms focus on:

  • Lack of rigour in customer due diligence
  • Insufficient information on source of funds
  • Over-reliance on third party due diligence (insufficient evidence from customers)
  • Poor record keeping

Caesars resolved the matters through a voluntary settlement with the Commission involving:

  • Remedial steps
  • The appointment of an audit firm to conduct an independent review at Caesars' expense of its AML policies and procedures
  • Publication of the attached statement to draw the issues to the attention of the wider industry to provide an opportunity for others to improve
  • An agreement to disseminate learning to the wider industry through seminars or similar
  • A significant payment (£850k) to be directed to socially responsible causes

The document makes for an interesting read and should be reviewed in detail by senior managers and especially Money Laundering Reporting Officers in all sectors, in particular non-remote and remote casinos.

As with other similar public statements in the past, the Commission will expect the wider industry to learn from the issues identified.

If you have any questions arising from this, please speak to your usual Mishcon contact or a member of our Betting & Gaming Group.