Written evidence submitted by the Gambling Anti-Money Laundering Group (GAMLG) submission

The Gambling Anti-Money Laundering Group (GAMLG) was established in January 2016 with the aim of improving the gambling industry’s ability to combat money laundering. Its membership was initially comprised of members of the Association of British Bookmakers (ABB), representing retail bookmakers, and the Remote Gambling Association (RGA), representing the online bookmaking market. In November 2019, the Betting and Gaming Council (BGC) was established bringing together the ABB, RGA and the National Casino Forum (NCF). The BGC continues to support GAMLG whose membership was expanded to include the BGC’s full membership – retail bookmakers, online operators, and the land-based casino sector.

All members of GAMLG adhere to best practice guidelines set out by the Group and comply with legal and regulatory requirements aimed at preventing money laundering or the spending of the proceeds of crime.

Since its inception, GAMLG has worked to identify and mitigate money laundering risks via the development of an industry-wide risk assessment and the development and dissemination of best practice in compliance and handling procedures. Areas identified as requiring improvement have informed the work of the Group and will continue to do so. Current areas of work include the development of training tools for members and the wider industry including the promotion and sharing of best practice in AML training and compliance across the sector; the development of a potential industry protocol relating to the divestment of funds in instances of regulatory failing; a review of common enhanced due diligence (EDD) thresholds and processes; and a solution to information sharing limitations met by the sector and law enforcement in this area.

GAMLG made a short submission to the previous enquiry undertaken by this Committee and welcomes the opportunity to update the Committee on its work since that point.

GAMLG has developed a series of best practice documents, for example, focussed on developing a consistent approach to engagement with customers and raising customer awareness about anti-money laundering policies in place in the retail sector. Information posters and leaflets were developed available across all member shops alongside consistent practices when requesting Know Your Customer (KYC) or customer due diligence (CDD) documentation.

Similarly, work was undertaken to develop consistency in approach to the enhanced due diligence (EDD) process amongst remote (online) operators outlining how a tiered approach to EDD might work when a particular threshold is triggered; and what a best practice EDD might look like.

Without exception, these processes sit alongside operator’s own processes and risk-assessments and serve as examples of best practice and guidelines.

Given the relatively recent inclusion of the land-based casino sector within GAMLG, these processes – where applicable – are currently under review for potential expansion to include this wider remit.

An issue which has remained on the GAMLG agenda for some time is the issue of datasharing within the sector. The current legal and regulatory regime does not provide for licensed gambling operators to exchange information with each other about suspicious activity of the kind that would lead to the submission of Suspicious Activity Reports (SARs). This seriously undermines its ability to effectively combat anti-money laundering (AML) and counter terrorist financing (CTF) threats.


The key reason for this is that the absence of an effective data sharing mechanism means that the risk from money launderers is being addressed on a piece-meal operator by operator basis rather than as a concerted industry-wide effort. This provides the opportunity for money launderers to: (i) move from one operator to another in order to avoid identification; and (ii) to spread their activities across a range of operators so that their level of activity with any one company may not be sufficient to register as suspicious activity.

To address this problem extensive discussions have been held with both the Information Commissioners’ Office (ICO) and the Gambling Commission. This has led to the unfortunate conclusion that there is nothing more that can be done within the existing legal constraints.

The Group has therefore focussed on potential legislative changes that might help realise the objective of sharing information amongst the regulated (for money laundering purposes) and non-regulated parts of the gambling sector.

The most obvious means by which to do so would be via amendment to the Criminal Finances Act 2017, the aim of which was to improve the ability to tackle money laundering and recover the proceeds of crime. The aim of GAMLG mirrors that of the Government in this legislation.

The Act introduced new sections 339ZB-339ZG into the Proceeds of Crime Act 2002 (POCA), and new sections 21CA to 21CF into the Terrorism Act 2000. These new provisions allow banks and other businesses in the regulated sector to share information, on receipt of a disclosure request from the NCA or another regulated business, in relation to a suspicion that a person is engaged in money laundering, suspicion that a person is involved in the commission of a terrorist financing offence, or in relation to the identification of terrorist property or its movement or use. However, these provisions do not allow for the sharing of information effectively within the gambling industry, which comprises the regulated and non-regulated sector.

Additional expert resource has recently been recruited to assist GAMLG in developing this workstream with a view to finding a solution – whether via potential legislative change or via alternative non-legislative means.

We would be happy to provide further information where helpful and to discuss any element of this submission in more detail.


November 2020