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much more efficiently and within a given context. GC: Obviously money laundering remains to be a serious and widespread crime. Would you say things are getting better with the most recent rules and regulations in place across the globe? MLK: Well, the issue often isn’t new regulation or the good intentions thereof. It is the fact that implementation lags behind too often. As the President of the FATF, Marcus Pleyer recently said: “Whereas most have put laws and regulations in place, many fail to use them effectively, if at all.” And, in that same speech he mentioned casinos just after banks and accountants. GC: There is also the dilemma that I have encountered often regarding the burdening of legal gambling operators compared to those that are functioning illegally as they might not have a license in a jurisdiction. And, there is often the issue of enforcement, whereby legal operators rightly complain that nothing is done against illegal operators who are, due to less regulator and taxation burdens, able to offer better odds and be more attractive. MLK: Yes, unfortunately that dilemma exists, and there is a strong necessity to have effective enforcement so as to mitigate the dilemma. But that does not mean that legally operating banks and casinos should not seek the need for high standard implementation. Overall, effective AML is a matter of attitude. In the end if criminals want to launder the money, I am sure they will find a way. The idea is to mitigate the channels for it to happening; to empower organisations to decrease the opportunities. And, not least within their own organisation. I can’t see that money laundering activities as a benefit to any business in the public eye. And, one important tool herein is raising awareness. GC: Yes, I fully agree. It’s very similar to how


are taking an interest in crypto. Often it is impossible to detect who is behind the transactions, especially with over 7,000 different virtual currencies around. And, the number is growing. The question herein is whether regulators and supervisors will be able to handle it. Estonia has become a hub for crypto


I see the debate around the integrity of sport, within which context of course there are strong elements of money laundering. Many sports betting operators and sports organisers take the matter very seriously. They don’t want to have empty stadiums – well, which you do have at the moment for other reasons – or annihilation of sponsorship because no one trusts the honesty of the game anymore. And, a quicksand dynamic here is that it is self-perpetuating. As you know, cryptocurrencies are a


strong focus for me, and I have had several interviews previously with Joachim Marnitz in Casino International about the technology and how it could influence the future of gambling transactions. Your and my common interest here was also another reason why we “hit the ground running.” You recently got an article published in a prominent Estonian newspaper about how money laundering is facing a major paradigm shift in light of crypto. What do you mean with paradigm shift? MLK: It is obvious that money launderers


currencies, and believe it or not, crypto ATMs are not difficult to find. In 2020 there were around 3,000 crypto licenses, making it at that point an indisputable market leader worldwide in the relevant exchange market. GC: But something happened recently which essentially killed off a lot of the licenses. Was it the EU’s 5th AML Directive? MLK: I believe these are the consequences of being innovative and the first to regulate crypto service providers activities. Estonia is among the first countries in the world to comply with AML5D requirements on virtual currencies. Implementation of the new regulations obliged crypto exchanges to register their activity with local Financial Intelligence Unit. A year ago, AML regulation was tightened, and many most of the licences were revoked. With the increased transparency forced upon virtual currency traders, a lot of confusion took place especially when it came to the new rules. The minimum share of a legal person was increased, a company engaged in trading was obliged to have a bank account with a financial institution in the European Economic Area, a physical presence in Estonia was also necessary either as a local representation or a local board member, an anti-money laundering officer with physical presence in Estonia was made obligatory, and so on and so forth. You can imagine the confusion.


Greetings from Brussels, #StaySafeStayTuned and don’t forget – #AskMariLiis.


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