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Volume 3, Edition 1                     Chatterbox                          07/04/2020







         Part Three: Enforcement Action                                               In Focus: FATF






                                                                                            ...continued
        2019 Round Up
                                                                                  • Increase use of the unregulated
                                                                                      financial sector, creating
                                                                                    additional opportunities for
                                                                                   criminals to launder illicit funds;

                                                                                   • Misuse and misappropriation
                                                                                    of domestic and international
                                                                                    financial aid and emergency
                                                                                             funding;
        As we move further into 2020, it is   The UK Gambling Commission is
        a good opportunity to reflect on the   continuing to report surprising      • Exploit COVID-19 and the
        misdeeds of last year.              and disappointing results from its     associated economic downturn
                                            supervision.
        More than $8 billion in fines were                                         to move into new cash-intensive
                                                                                      and high-liquidity lines of
        handed out in 2019 for AML          On 2nd April 2020 the Commission      business in developing countries
        misdemeanors, most from the USA     reported that Caesars Entertainment
        and UK.  Compared to 2018, this was   UK Limited had been fined the sum of    https://www.fatf-gafi.org/
        a bumper year for regulators who    £13m following a catalogue of social      publications/fatfgeneral/
        handed out a mere $4 billion worth of   responsibility, money laundering and   documents/covid-19-ml-tf.html
        penalties during that period.       customer interaction failures including
                                            those involving ‘VIPs’.
        Interestingly in this year on year   Money laundering failings included:
        comparison, there is somewhat of a                                      Since January the Commission has
        correlation between the number of   • The operator not carrying out     suspended the operating licences
        fines and the value of fines with 29   adequate source of funds checks on   of Stakers Limited, Addison Global
        fines handed out in 2018 compared   a customer who was allowed to drop   Limited, and International Multi-
        to 58 in 2019.  Another item of note   around £3.5 million and lose £1.6   Media Entertainments Limited and so
        is that whilst the UK and the US are   million over a period of three months.  far, this year regulatory action has led
        handed out the most fines (12 and   • The operator not obtaining adequate   to the industry paying £27 million in
        25 respectively), the value of these   evidence of source of funds for a   penalty packages. This includes £11.6
        pales into insignificance against a   politically exposed person (PEP) who   million for Betway and £3 million for
        whopping $5 billion fine levied by the   lost £795,000 during a 13-month   Mr. Green.
        French courts at one single entity –   period
        UBS.  UBS is poised to fight the ruling   • The operator not carrying out   Keep it up!
        but nonetheless it highlights the   enhanced customer due diligence
        increasing appetite of all international   (ECDD) checks on a consumer who   http://www.gamblingcommission.
        regulators and enforcement bodies to   lost £240,000 over a 13-month period  gov.uk/news-action-and-statistics/
        hold firms to account for alleged poor   • The operator not carrying out   News/systemic-failings-at-caesars-
        conduct.                            adequate source of funds checks on a   entertainment-leads-to-the-
        Let’s see if 2020 shapes up the same   customer who identified as a waitress   departure-of-three-senior-managers-
        way.                                and was allowed to buy-in £87,000   and-sanctions-of-13m
                                            and lose £15,000 during a 12-month
        https://thefintechtimes.com/aml-    period.
        a-shocking-8-14-billion-of-fines-
        handed-out-in-2019/







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