Evolution or Revolution, The Quandary Of AML Compliance
In recent years it seems that for many operators the shift to prioritising Safer Gambling has led to a decrease in Anti-Money Laundering (AML) focus.
Could this be part of the reason why so many fines that we see are still very much based on AML failings?
Take a look globally at enforcement action. Recently we have seen penalties for what many of us would consider to be AML basics: Not having up-to-date risk assessments, a competent MLRO, a lack of appropriate risk management tools.
This begs a host of questions. Are operators finding it difficult to strike the right balance? Are AML regulations just deemed less important for some operators? Has training been put on hold to focus on Safer Gambling?
And finally, perhaps the most important question of all: Why is it that–despite some great examples of AML best practice, and high amounts of investment–we as an industry still seem to fall short of expectations and requirements?
Of late the gambling industry has been navigating a significant shift in priorities, with a growing focus on promoting Safer Gambling practices.
While AML compliance has traditionally been a top priority for operators, the industry is increasingly recognising the importance of a balanced approach that prioritises player welfare and Responsible Gaming. This evolution reflects a broader understanding that safeguarding customers and maintaining the integrity of the industry go hand-in-hand. Yet often prompted by political pressure, our collective desire for positive change, and negative public perceptions of the gambling industry, enforcement can sometimes level a heavy cost.
Fines from regulators due to AML and Safer Gambling breaches are more prevalent than ever. Whilst getting Safer Gambling Compliance right can be a challenge, AML Laws have been around for decades and, for the most part, their enhancements have always been pretty clear.
I asked some of my peers why they thought that something so essential, such as a Business Risk Assessment, is hard to comply with.
The common answer was that there was “a lack of clarity”, that requirements were not made clear by statutory authorities. The same fault was noted when it came to finding appropriate customer financial thresholds, concurred my pool of experts.
To an extent I agree with their consensus. But, crucially, I also believe that we are not learning the lessons revealed by enforcement action. If we were, we would not see such similar repeated failings. Thus we have to ask: What can the gambling industry do to get this right?
The Safer Gambling Imperative
Our industry has long grappled with concerns related to addiction, player harm, and Safer Gambling – all made more prescient by government pressure and a general lack of public trust in our industry.
The recognition of these issues has led to a change in the way operators view their responsibilities. With an emphasis on promoting Safer Gambling, operators aim to create an environment where customers can enjoy the experience without succumbing to gambling harms.
I believe the industry has reacted well to these challenges, with operators acknowledging their role in protecting vulnerable individuals and the broader public.
This regulatory evolution has reshaped the priorities of the gambling industry.
Today, operators are increasingly required to invest in Safer Gambling measures, creating an environment where AML compliance and Responsible Gaming coexist as essential components of their business.
But the balancing act, and never-ending challenge, between Proactive vs Reactive Compliance is also falling short.
Traditionally, AML compliance has focused on detecting and mitigating financial crimes after they occur. In contrast, the emphasis on Safer Gambling is more proactive, concentrating on preventing harm before it happens. Operators are increasingly investing in technologies and resources to identify and support players who may be at risk of developing gambling-related problems.
In many cases, this is also being packaged as a way to manage AML risks.
But the reality is that–whilst there is some crossover–there has been an overall decrease in investment on many AML products and services in the industry – compounded by a shortage of good training providers.
Training–and enhancing the knowledge of our employee teams–needs to be back at the top of our agenda, or we run the risk of limiting critical knowledge to just a handful of experts.
And here I’m not talking about tick-a-box e-learning courses but real face-to-face, hands-on, training that delivers results to benefit operators, customers, our industry as a whole.
Technology is playing a pivotal role in facilitating this shift. Advanced data analytics, artificial intelligence and machine learning are enabling operators to identify early-warning signs of problematic gambling behaviour. These tools can help operators intervene to provide support, guidance and restrictions for customers at risk.
Moreover, the adoption of digital payment methods and blockchain technology can enhance transparency in financial transactions, addressing AML concerns; while preserving the integrity of the gambling industry.
Evolving priorities, with a stronger emphasis on Safer Gambling, represent a significant step towards ensuring the well-being of players and the longevity of the sector.
But while AML compliance remains vital in safeguarding the industry from financial crimes, it is no longer the sole focus. Instead, it is part of a broader strategy that prioritises the prevention of harm and the responsible conduct of gambling operations.
We need to ensure equilibrium where Safer Gambling, AML and Data Security are given equal priority within the industry.
Only by harnessing technology, adopting proactive measures, and enabling adequate training, can the gambling industry move forward to a future where AML compliance and Safer Gambling coexist, benefiting both operators and the public at large.