One of the joys of writing a blog is that it’s like having an informal team of researchers, or moles even, looking out for money laundering stories for me. I adore anti-money laundering as you know, but I’m just one person and I can’t read everything on the subject, so these extra eyes are invaluable to me. And last week top mole Tess in the Isle of Man sent me a link to this story about the Irish gambling sector.
I do quite a bit of work for gambling regulators, one way or another, both bricks and clicks, so I was very surprised to read that the Irish gambling sector has no AML supervisor. Gambling businesses in Ireland – casinos, dog-tracks and betting shops, for instance – do have to get a licence, which entails a fit and proper test, but they are not covered by the local AML requirements (as defined by the Criminal Justice [Money Laundering and Terrorist Financing] Act 2010) and have no AML supervisor. Crucially – and this is the main thrust of the article that Tess spotted for us – they are under no obligation to report suspicious transactions.
Now doesn’t this seem like something of a large gap in the Irish provisions? A piece of legislation intended to address this was put out in draft form in July 2013: the Gambling Control Bill. This would create a new regulatory authority, issue licences, prohibit super-casinos (with more than fifteen tables) and much more, intended to protect the sector from criminal infiltration and its customers from gambling addiction. Sadly, the bill has not progressed an inch, and none of these proposals has been implemented.
I am a simple creature at heart, and I find this confusing. I know we’re all about the Fourth Money Laundering Directive these days, but cast your mind back to its predecessor. And Article 10 of the Third Money Laundering Directive says: “Member States shall require that all casino customers be identified and their identity verified if they purchase or exchange gambling chips with a value of €2,000 or more.” So just how has Ireland been checking that this has been done since 15 December 2007 – the implementation deadline of MLD3 – without an AML supervisor?