The risks, preventative measures
and operational actions from the
perspective of an international
betting operator
11 December 2012
David Norman
Global Head of AML/MLRO
CONFIDENTIAL and not for reproduction without prior written
consent © of the author
PERCEPTION
• Internet gaming/betting is at risk from money laundering
• Why?
–
–
–
–
–
it is anonymous
non face to face business
funds are able to be moved globally very quickly
organised crime has a substantial stake in internet gaming companies
because of the volume, speed, anonymity, and international reach made
possible by internet transactions (Brian Deese, deputy director of the
National Economic Council, USA)
CONFIDENTIAL and not for reproduction without prior written
consent © of the author
2
THE EVIDENCE
• To support the perception
• there is no credible evidence to suggest that internet betting/gaming
companies have been used as a vehicle to for money laundering
• To refute the perception
• there are no prosecutions world-wide where internet gaming companies
have been used as a money laundering vehicle to launder the proceeds of
crime
• every single action/key stroke an internet gaming customer makes is
recorded and can be monitored
• three studies in recent years have concluded that internet gaming presents
minimal money laundering risk
– The threat of money-laundering and terrorist financing through the online gambling industry”;
a report prepared for the UK Remote Gaming Association by MHA Consulting, June 2009.
– Money-Laundering Risks and E-Gaming: A European Overview and Assessment”; by Michael
Levi, Ph.D., D.Sc. (Econ.), Professor of Criminology, University of Cardiff, September 2009.
– Can Internet Gambling Be Effectively Regulated? Managing the Risks; by Malcolm K. Sparrow
John F. Kennedy School of Government, Harvard University, December 2009
CONFIDENTIAL and not for reproduction without prior written
consent © of the author
3
BALANCED, RISK BASED,
PROPORTIONATE
CONFIDENTIAL and not for reproduction without prior written
consent © of the author
4
SPORTING INTEGRITY & MONEY
LAUNDERING
•
Ability to ‘Follow the money’. Every transaction is recorded.
•
Is there a reasonable explanation for the betting or is there
•
Detailed Investigation of suspect betting and accounts.
any reason to be suspicious?
• Monitoring betting markets and events in real-time at account
level.
• Action taken against suspect accounts; suspension of account and
freezing of winnings.
CONFIDENTIAL and not for reproduction without prior written
consent © of the author
5
DEFINING INTERNET BETTING/GAMING
Country
Interpretation
CDD
Denmark
Casinos
Internet Casinos/Betting
Within 1 month of registration not 5 years
to exceed DKK10,000 until CDD
France
Online poker game operators .
Groups, clubs and companies organising games of chance,
lotteries, sports or horse race betting.
On registration within 30 days.
5 years
Italy
Casinos, gambling and betting parlours.
Online betting operators
Cumulative deposits in excess
€1,000 (before)
10 years
Malta
Casinos/Internet Casinos/Remote Gaming Regulations
Risk Based?
ASAP
5 years
Spain
Casinos
Persons responsible for the management, operation and
marketing of lotteries or other gambling activities in
respect of prize payment transactions.
Within 30 days of registration.
10 years
UK
Casinos/Internet Casinos.
Exchange of chips in excess of
€2,000 on daily basis
5 years
Gibraltar
All forms of remote gambling.
On deposit 60 days
5 years
CONFIDENTIAL and not for reproduction without prior written
consent © of the author
Record Keeping
6
David Norman
Global Head of AML/MLRO
CONFIDENTIAL and not for reproduction without prior written
consent © of the author