UK LEGAL COMMENT
Emerging risks for UK gambling operators
A SARs
The Commission highlights the increase in SARs submissions during the Covid-19 pandemic and reminds operators of the need to submit a key event whenever a SAR is submitted. The UKFIU saw a 20% increase in the number
20 JUNE 2021
s UK casinos re-open, grappling with how best to address Covid risks (Perspex screens and sanitised gaming chips are now the norm), the Gambling Commission has warned of new “emerging risks”. These include risks relating to
inadequate SAR submissions and customer due diligence. The Commission’s latest update on to its customer interaction and affordability consultation also highlights that operators may need to assess risks relating to customers’ “financial vulnerability”.
of SARs in the 19/20 financial year (with a 24% increase from the gaming sector) and an 81% increase in requests for a defence.
The National Crime Agency has published guidance on “submitting better quality SARs”. In particular, when seeking consent to continue with a transaction, the NCA says that it is essential that the following information is included: • the information which gives the basis for knowledge or suspicion,
• a description of the property that is known/suspected/ believed to be criminal property,
• a description of the prohibited act that consent is needed for (e.g. processing a withdrawal request),
• the identity of the person(s) suspected to be involved in money laundering,
• the current whereabouts of the funds in question.
Northridge Law’s Melanie Ellis looks at the latest issues affecting the UK industry
wirojsid/Adobe Stock
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