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EU Bytes


Former Executive Director of the European Casino Association and current Managing Director of Time & Place Consulting, Glenn Cezanne provides the latest info on what’s trending and what’s coming down the pipeline in Brussels and around the EU.


H 4TH AMLD RE-CAP


A quick re-cap of some key points that the 4th AMLD brought with it: 1 Previously, focus of AML was primarily on


casinos. The 4th AMLD concerns all forms of gambling services whereby member States can fully or partially exclude specific forms of gambling as long as they have been risk-assessed as low risk. Casinos are not subject to this form


Glenn Cezanne


of exclusion. 2 Therefore, we saw a general move towards a risk-based approach for the whole gambling sector. This includes questions of beneficial ownership and enhanced customer due diligence.


3 Specifically, when looking at stakes and winnings this means that customer due diligence would have to be performed on the


ere in Brussels the new Members of the European Parliament are settling in and the European Commission is up for a change at the end of October. Also, the same day as


Halloween, I mean Brexit. So, in a way, all is normal, well at least some things are. Grey skies and constant search for brighter futures. In this month’s edition, we are looking at one of


the hottest topics affecting the gambling industry: EU anti-money laundering rules. I am sure many of you still remember the long-winded debates surrounding the 4th Anti-Money Laundering Directive which finally became an act in 2015 and was transposed into law by June of 2017. And, I am sure many of you are still very much involved in the aftermath of the rules and regulations that came with the Directive. I notice more and more demand for compliance officers throughout the gambling world.


amount of EUR 2,000 or more. 4 An extension of the definition of Politically Exposed Persons – i.e. someone with a significant public function and their closer family members and associates. All national PEPs were included because of risk exposure tied to their functions.


WHAT THE COMMISSION RISK ASSESSMENT IS ABOUT


On 24 July 2019, the European Commission published its second supranational risk assessment; the first having been published in 2017. The 4th AMLD sets out that the Commission is to conduct an assessment of money laundering and terrorist financing risks which affect the EU’s internal market and cross-border activities at least every two years. Not a small task as it looks at “vulnerabilities identified at EU level, both in terms of legal framework and in terms of effective application and provides recommendations for addressing them”. Before I go on, I would like to also remind you of the 5th AMLD which is supposed to be transposed by January 2020. The 5th AMLD looks at prepaid cards, providers of exchange services and custodian wallet providers (think cryptocurrencies), transaction with high-risk third countries, and beneficial ownership registers. The introduction of the 5th AMLD primarily derives from the terrorist attacks across Europe in the last years and was overwhelmingly backed by the European institutions. Why is this of interest in our current discussion? The European Commission has already been anticipating the 5th AMLD when defining the measures for mitigating money laundering in its current risk assessment. The recent risk assessment identified 47 products and services that are potentially


34 OCTOBER 2019


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