Anti Money Laundering and (Online) Gaming: How to Implement Broad and Indistinct AML Notions - Regulatory Experiences from Europe

Target audience: Gaming regulators, gaming companies (notably compliance officers), scholars. Research questions: This UNLV supported research project has combined valuable inputs from international AML experts, gaming regulators with significant online and AML experience and AML literature alike. It has notably addressed the following questions: How are broad and indistinct AML notions - referring to higher money laundering risk constellations - to be interpreted in the (online) gaming sector specifically? How can regulators implement these AML notions proportionately (effectiveness without unnecessary regulatory over-kill)? What solutions are available to mitigate the AML risks? Research background: Both gaming regulators and gaming companies are facing the challenge of implementing increasingly strict AML requirementsthat are driven by laws of international organisations (FATF, EU, MONEYVAL). These AML laws refer to circumstances of “higher” money laundering risks, in which obliged entities are required to apply enhanced customer due diligence. However, one of the challenges consists in the fact that these AML laws have general applicability (they are not gaming sector-specific) and their key notions are often broad and indistinct. Accordingly, gaming regulators and gaming companies alike may struggle in how to interpret and implement them in the gaming sector. For instance, enhanced customer due diligence is required when “the business relationship is conducted in unusual circumstances”(4thEU AML Directive). Yet, what is “unusual” supposed to mean in the gaming sector specifically? Gaming regulators may further wonder, how they can specify effective AML requirements without unnecessarily burdening their gaming industry. At the same time, regulated land-based and online operators have a vital interest in fully being compliant with AML rules. The detrimental consequences for non-compliance can reach from very high fines, significant reputation risk, freezing of customer accounts, withdrawal of the operator’s license to administrative and criminal prosecution of AML officers subject to minimum sentencing rules

What we know about the impact of advertising on disordered gambling

Towards the end of 2011, the (then) Responsible Gambling Fund published a report which, inter alia, offers an overview of the research gaps in relation to the impact of advertising on disordered gambling. In this article, the authors of the report summarise their main findings. They conclude that evaluating the impact of gambling advertising is highly complex. Nonetheless, advertising forms an important component of the broader environment in which behaviour and attitudes are shaped. The empirical evidence base is weak and therefore conclusions about whether gambling advertising is associated with increased levels of disordered gambling cannot be drawn. However, there is some evidence that advertising alters perceptions and attitudes towards gambling. Yet, evidence demonstrating translation of this into behavioural change is weak. Particular attention should be given to vulnerable population groups such as adolescents and disordered gamblers. In view of further research, a set of recommendations is provided

What we know about the comparative effectiveness of gambling regulation

Towards the end of 2011, the Responsible Gambling Fund published a report which, inter alia, offers an overview of the research gaps in relation to the comparative effectiveness of gambling regulation. In the present article, the authors of the report provide a summary of the main findings. They conclude that hardly any empirical evidence is available that addresses, directly or indirectly, this subject. In view of further research, a set of recommendations is provided