Date: 03.10.2023

by Mateusz Mazur

Introduction of Player ID in Land-Based Betting Requires Gambling Operators to Reassess AML and CFT Risk

On October 1, 2023, a new requirement mandated that all land-based betting operators must identify customers before they can place bets in physical retail locations. This identification process includes issuing a Player ID linked to an account.

The introduction of the Player ID and associated accounts has significant implications for the business models of gambling operators. They are now obligated to assess whether these changes alter their inherent risk of being misused for money laundering and terrorist financing.

Regular Risk Assessments

As a general rule, gambling operators are required to reassess their risk profile at least once a year or when significant changes occur in their business model. The introduction of the Player ID necessitates an updated risk assessment, which, in turn, informs the adaptation of policies, business procedures, and controls.

Gambling operators must evaluate the potential for misuse of the Player ID and its impact on the risk of money laundering and terrorist financing within their operations. They need to determine the appropriate mitigation measures to reduce the risk of Player ID misuse.

Addressing Risks Associated with Customer Accounts

Operators should also consider the risks associated with providing customers with accounts, especially in the context of paying out winnings to these accounts. Measures must be identified and implemented to mitigate the risks associated with customer accounts.

In conclusion, the introduction of the Player ID requirement for land-based betting operators necessitates a comprehensive reassessment of their anti-money laundering (AML) and countering the financing of terrorism (CFT) risk profiles. Operators must identify and mitigate the potential misuse of Player IDs and address risks associated with customer accounts to ensure compliance with regulatory requirements and maintain the integrity of their operations.

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