THE ASSESSMENT REPORT
Regulation would ensure ‘word-for-
word’ consistency. If the EU issues a regulation it
becomes national law the moment it has been made public. The law would appear in every EU member state in exactly the same
form. However, while we know the EU is planning to regulate AML in the future, presently there will be a sixth AML
directive published on the single topic of cryptocurrencies.
Supranational Risk Assessment looks at different sectors, those that might be susceptible to money laundering, and gives each a risk value, which is used by European Union institutions as a guide to dealing with businesses and individuals in these sectors. Te Supranational Risk Assessment tells a bank, for example, how they should handle businesses within these high risk sectors as regards to compliance. Te fact that this is guidance and not regulation, means that there is a great deal of latitude in the interpretation of the assessment report on the part of these institutions. Financial institutions formulate their own risk tolerances and individually implement measures in response to the risk levels outlined in the report. Ultimately, the Supranational Risk Assessment has an impact on how businesses are able to conduct their operations within the European Union. If you have a high risk business, everything becomes much, much harder.
Te Supranational Risk Assessment is a service the EU conducts for its members. It gives an indication for the risk within individual sectors and lets the
P72 WIRE / PULSE / INSIGHT / REPORTS
member states manage this risk for themselves. In order to minimise the risk, the directive concludes that measures should be implemented that remain within the remit of the individual nation states. Risk assessment is something all companies must complete as the Supranational Risk Assessment gives an indication of what is high risk and what measures you should implement to avoid potential threats.
Te directive is simply a recommendation. In the field of anti-money laundering, the EU has learned that this implementation varies to a wide extent within the European Union. Variation means that some countries have weaker regulations, while others have much stricter ones, which delivers a competitive advantage within the Union. A country with weaker AML implementation equals less investigation of funds etc. which is one of the reasons why we’ve seen five AML directives to date, and why the EU is currently working upon the sixth incarnation of this guidance.
As opposed to guidance, new regulation is a possible route the EU could follow in the future as
regards to AML, since regulation would ensure ‘word-for-word’ consistency. If the EU issues a regulation it becomes national law the moment it has been made public. Te law would appear in every EU member state in exactly the same form. However, while we know the EU is planning to regulate AML in the future, presently there will be a sixth AML directive published on the single topic of cryptocurrencies. Te EU has yet to put cryptocurrencies within its regulation package, but until it does, cryptocurrency will have its own AML directive.
THE SRA EFFECT ON LAND- BASED CASINO OPERATORS
Te impact in 2017 was a shock. Te assessment claimed that the risk of money laundering was a ‘given’ because cash is converted into chips and then transferred back into cash within a casino, which was assessed to represent the highest money laundering risk. Te general industry view was that this assessment did not take into consideration all the money- handling processes that take place within casinos.
Te land-based industry was, understandably, very critical of the first Supranational Risk
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84 |
Page 85 |
Page 86 |
Page 87 |
Page 88 |
Page 89 |
Page 90 |
Page 91 |
Page 92 |
Page 93 |
Page 94 |
Page 95 |
Page 96 |
Page 97 |
Page 98 |
Page 99 |
Page 100 |
Page 101 |
Page 102 |
Page 103 |
Page 104 |
Page 105 |
Page 106 |
Page 107 |
Page 108 |
Page 109 |
Page 110 |
Page 111 |
Page 112 |
Page 113 |
Page 114 |
Page 115 |
Page 116 |
Page 117 |
Page 118 |
Page 119 |
Page 120 |
Page 121 |
Page 122 |
Page 123 |
Page 124 |
Page 125 |
Page 126 |
Page 127 |
Page 128 |
Page 129 |
Page 130 |
Page 131 |
Page 132 |
Page 133 |
Page 134 |
Page 135 |
Page 136 |
Page 137 |
Page 138 |
Page 139 |
Page 140 |
Page 141 |
Page 142 |
Page 143 |
Page 144 |
Page 145 |
Page 146 |
Page 147 |
Page 148 |
Page 149 |
Page 150 |
Page 151 |
Page 152 |
Page 153 |
Page 154 |
Page 155 |
Page 156 |
Page 157 |
Page 158 |
Page 159 |
Page 160 |
Page 161 |
Page 162 |
Page 163 |
Page 164 |
Page 165 |
Page 166 |
Page 167 |
Page 168 |
Page 169 |
Page 170 |
Page 171 |
Page 172 |
Page 173 |
Page 174 |
Page 175 |
Page 176 |
Page 177 |
Page 178 |
Page 179 |
Page 180
