iGaming Compliance: Making Sense of the Multi-Jurisdictional AML Program

In iGaming–or indeed in all regulated gambling–there’s one indubitable truth: Anti-money laundering provisions take centre stage in global licensing requirements, writes Sonia Wasowska, Compliance Director and MLRO at Crucial Compliance

The multi-jurisdictional nature of the iGaming industry is evident in the growing market for B2B providers in compliance business operations, along with the increasing collaboration efforts demonstrated by regulators. 

AML and sports integrity remain areas of ongoing focus in jurisdictions where considerations for safer gambling regulations are just beginning to emerge, and AML-related breaches consistently feature in enforcement action publications, underscoring the need to scrutinise AML programs more closely.

This article explores the challenges and best practices for building an AML program in the iGaming industry. 

We will focus on outlining the main components of an AML framework, looking at the challenges of a multi-jurisdictional operator and explore how innovative solutions from compliance tech providers, such as Crucial Compliance, can ensure a more robust ongoing risk management approach – and provide much-needed stability for business growth.

The Global Landscape

In the ever-evolving world of online gaming, compliance with Anti-Money Laundering (AML) regulations is critical. As iGaming operators expand their reach across multiple jurisdictions, the need for a robust and adaptable AML program becomes increasingly important.

iGaming has grown exponentially over the past decade, with millions of players engaging in various forms of online betting and gambling. As a result, the industry has attracted the attention of regulators worldwide, who are keen to ensure that operators do not unwittingly facilitate money laundering and other financial crimes. Complying with variables of requirements and specific adjustments can be a complex and costly task, but it is essential for maintaining the integrity of the industry and avoiding legal repercussions.

To effectively address the challenges of multi-jurisdictional AML compliance in the iGaming industry, operators can follow these best practices:

Governance Documentation:

Thorough documentation of all relevant aspects of your AML program is key. 

Evidencing that the regulatory requirements are understood and translated into business-specific policies and processes together with ongoing risk assessments and underlying escalation and reporting routes provides necessary regulatory assurances.

Risk Assessment Process:

Conducting a thorough risk assessment specific to each jurisdiction in which you operate–as well as demonstrating that one is addressing emerging risks– is key. Understand the unique money laundering risks associated with each region, and tailor your AML program accordingly. This is the one key element that all your policies and processes stem from.

AML Team Positioning: 

Establish a dedicated compliance team, or hire a third-party AML compliance provider with expertise in the iGaming sector. Consider where this team sits in your structure to enable collaboration with other teams and support the ongoing exchange of information.

Adaptable AML Policies and Procedures:

Develop AML policies and procedures that demonstrate relevance to your products and sector-specific risks in line with up-to-date, jurisdiction-specific guidance, and best practices.

Technology and Data Management/Operational AML Models:

Consider the benefits of a lifetime risk rating model and appropriate automation for the purpose of trigger and risk alert management.

Customer AML Risk Assessments:

Documentation of ongoing risk assessments is key to proving your team’s day-to-day work. But also ensures documentation of all decision-making in a risk-based approach application process.

Advanced AML Software:

Invest in advanced AML software solutions that can automate customer screening, transaction monitoring, and reporting. These tools can help manage the vast amount of data involved in AML compliance.

Training and Education:

Regularly train and educate your staff about the importance of AML compliance and the specific requirements of each jurisdiction. Appropriate practical and specific training promotes better decision-making, and allows for more confident risk management.

Cross-border Cooperation: 

Engage in open communication and cooperation with regulatory authorities in multiple jurisdictions. Being proactive in addressing concerns and seeking guidance can help build a positive relationship with regulators.

Horizon Scanning/Periodic Audits, Reviews:

Conduct regular audits and reviews of your AML program to identify and rectify any shortcomings. Third-party assessments can provide an objective evaluation of your program’s effectiveness.

In conclusion, multi-jurisdictional AML compliance is a non-negotiable requirement for iGaming operators who want to maintain their reputation, avoid legal troubles, and continue expanding into new markets. 

While the challenges are formidable, a proactive and adaptable approach can help operators build effective AML programs that align with the requirements of each jurisdiction. 

At Crucial Compliance we support our clients with all their needs, building AML programs from scratch, providing independent audits, and supporting optimisation and automation via our risk management platform and AML model. The goal is to empower your operational teams with meaningful insights, providing a sophisticated system that not only assigns customer risk ratings but also integrates a proactive network of alerts and triggers.

By conducting comprehensive risk assessments, investing in advanced technology, and maintaining a dedicated compliance team, iGaming operators can stay ahead of evolving AML regulations and contribute to the integrity of the industry. 

Adherence to AML standards is not just a legal obligation but a commitment to responsible gaming and financial transparency that benefits both the operators and their players.

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