In recent months I have found myself working more and more frequently with the gambling sector – both e- and land-based casinos. Therefore I have been tracking the activities and pronouncements of the Gambling Commission more closely than before. And in May 2016 they published new requirements – in the form of an update to their existing licence conditions and codes of practice (LCCP) – around the prevention of crime association with gambling (including, of course, money laundering).
These changes come after a series of failures in the gambling world. In August 2014, a shop manager in a London branch of bookies Paddy Power became concerned that a customer was using gambling facilities to launder Scottish bank notes by placing them into gaming machines and then requesting a pay out on a debit card. The manager told his boss, but no SAR was made to the MLRO, and the worrying behaviour continued for another six months until publicity from police about the laundering of Scottish notes in London prompted the company to report the matter to the NCA. There were also concerns that Paddy Power had not made sufficient enquiries into the source of funds of another customer, who had been jailed for fraud, and in February 2016 Paddy Power was fined by the Gambling Commission. At around the same time, Gala Coral Group was providing gambling services to an electrician who eventually paid in £850,000 – without checking his source of funds, they missed the fact that he was stealing from a vulnerable adult. They too were fined by the GC. And at the same time again, accountant Matthew Stevens was gambling with Betfred, who welcomed him as a VIP player and did not check the source of his £850,000 – stolen from his employers. Again, a fine from the GC.
Well, the GC has had enough of finding out about things from third parties. And in their new requirements, which will come into force later this year, gambling operators “must report to the Commission any criminal investigations involving them or their premises where it appears their measures to keep crime out of gambling have failed”. Guidance of course will be needed, otherwise casinos will find themselves having to report every pilfered chip from the gambling table, and every phone taken from someone’s jacket pocket.