Course Summary
This foundation course will provide you with real-life case studies and introduce you to the principles underpinning financial crime prevention. In addition, it will enable you to understand the risks unique to licensed gaming operators and which controls can be best applied to successfully mitigate them.
This course will enable you to learn how to:
• Differentiate between the types of financial crime.
• Identify financial crime risks specific to your business.
• Implement a robust risk management program.
• Determine the key information you need to collect from your customers.
• Identify and escalate suspicious activity.
Participants of this course may be learning about financial crime for the first time, or perhaps are looking to enhance their existing experience with practical training, with the aim of advancing to study CAMS – the gold standard in AML certifications.
1. Getting Started
Introduction
• Instructions
• Introductory case video
• What would you do
• Feedback
• Learning objectives
2. What is financial crime?
Types of financial crime
• What is financial crime?
• Money laundering
• AML (Case example)
• Terrorist financing
• Bangladesh jihadism (Case example)
• Sanctions
• Sanctions screening case example Amazon (Case example)
• Fraud
• Fraud (Case example)
• Anti-bribery and corruption
• ABC (Case example)
• Tax avoidance vs tax evasion
• Tax avoidance vs tax evasion: Panama Papers (Case example) Review
• Review questions
3. Risk from financial crime
What is risk?
• Types of risk: Regulatory, legal, financial, reputational
• International regulations and guidance for gaming
• Categories of risk: Customer, jurisdiction, product, channel
• Customer risk and red flags
• Politically exposed person risk and red flags
• Beneficial ownership
• Ultimate beneficial ownership
• Shell company risk and red flags
• Customer type risk and red flags in gaming
• Jurisdiction risk and red flags
• Jurisdiction type risk and red flags in gaming
• Product risk and red flags
• Product type risk and red flags in gaming
• Channel risk and red flags
• Channel type risk and red flags in gaming
Risks specific to your business
• Land based casinos: Vancouver model (Case example)
• Sportsbetting (Case example)
• Online gaming (Case example)
• AML for gaming (Case example)
• CFT and sanctions in gaming (Case example)
• Fraud in gaming (Case example)
• Spending ill gotten gains in gaming (Case example)
• Casinos and trafficking (Case example)
Risk-based approach
• Risk-based approach to business
• Controlling risk • Residual risk equation
• Risk-rating by applying your institution’s policies and tools
Review
• Review questions
4. Compliance roles
Know your role in compliance
• Three lines of defense for gaming
• Role of surveillance in casinos
• Risk-based escalation
• Dual controls
• Independence of the second line
• Role of MLRO
• Audit as the third line of defense
Review
• Review questions
5. Risk management programs
Know Your Customer
• KYC is intended to manage risk
• KYC for gaming (Case example)
Transaction monitoring
• Transaction monitoring is intended to manage risk
• Transaction monitoring process
• Transaction monitoring alerts in gaming
• Transaction monitoring (Case example)
Sanctions compliance
• Who imposes sanctions
• Internet search: Sanctions screening
• Transaction monitoring vs name screening •
Consequences: Regulatory, financial, reputational (Case example)
Review
• Review questions
6. Due diligence
Research process
• Investigative mindset
• Four research steps
• Levels of due diligence
• CDD for a natural person
• CDD for a legal person
Information sources
• Criteria for selecting standard customer research sources
• If you need more information
• Tipping off
Organizing what you learn
• How much research is reasonably enough?
• Following organization-specific policies and procedures
• Filter what customer information is relevant and important (industryspecific)
• Data security and privacy
• Documenting your research
• Customer profile structure and format
Review
• Review questions
7. Actions
Your obligation
• Duty to report
• Suspicious activity escalation process • Suspicious activity escalation process for gaming
• Other reporting and record keeping obligations in gaming
How your organization might act
• What is a SAR/STR?
• Who writes a SAR in your organization?
• Transaction monitoring and ongoing reviews
• Post SAR/STR activity
Review
• Review questions
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