Combating Cybercrime In Betting And Gaming - Creating A More Effective Anti-Money Laundering Strategy

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Combating Cybercrime In Betting And Gaming - Creating A More Effective Anti-Money Laundering Strategy

Article by Monty

Raphael, Joint Head of

Fraud and Regulatory, Peters & Peters

NCIS, the forerunner of SOCA, and the Financial Action Task

Force have both highlighted the gaming sector as vulnerable to

money laundering. This vulnerability has not lessened, and

indeed may have increased, with the advent of cybergaming.

Cybercrime has exploded to cover all aspect of commercial

activity in cyberspace and the challenge for law enforcement is

the same for all sectors:

The delinquent activity is borderless

The activity is encouraged by the protection of being non

face-to-face

As cybercrime generates more and more criminal property,

it has to be laundered; where better than in the virtual

world in which it was created.

These are among the concerns that led the US congress to

outlaw e-gaming last year. What are the crucial elements of an

anti money laundering checklist in the UK? It is important to

adopt the risk based approach contained within the Money

Laundering Regulations 2007; for senior management to take

responsibility for managing risk, and for operators to carry

out customer due diligence obligations, record-keeping and,

ultimately, to identify and report suspicious activity.

1. The Financial Action Task Force Typologies

In its 1997-1998 Typologies Report, FATF recognised that

there had been a proliferation of laundering cases in the

casinos and gambling part of the non-financial sector. Casinos,

they said, are the site of the first stage in the laundering

process, i.e. converting the funds to be laundered from

banknotes (circulating currenc...

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