FATF Guidance on the Risk-Based Approach for Casinos

In October 2008, the FATF adopted Guidance on the Risk-Based Approach (RBA) to combating Money Laundering and Terrorist Financing for casinos. This Guidance was developed by the FATF in close consultation with representatives from the casinos sector. This guidance supports development of a common understanding of what the RBA involves, outlines high-levels principles involved in applying the RBA, and indicates good practice for governments and legal professionals in the design and implementation of an effective RBA.

The purpose of this Guidance is to:

• Support the development of a common understanding of what the risk-based approach involves.
• Outline the high-level principles involved in applying the risk-based approach.
• Indicate good practice in the design and implementation of an effective risk-based approach.

However, it should be noted that applying a risk-based approach is not mandatory. A properly applied risk-based approach does not necessarily mean a reduced burden, although it should result in a more cost effective use of resources. For some countries, applying a rules-based system might be more appropriate. Countries will need to make their own determinations on whether to apply a risk-based approach, based on their specific money laundering / terrorist financing risks, size and nature of the activities of the designated non-financial businesses and professions (DNFBPs), and other relevant information. The issue of timing is also relevant for countries that may have applied anti-money laundering/combating the financing of terrorism (AML/CFT) measures to DNFBPs, but where it is uncertain whether the DNFBPs have sufficient experience to implement and apply an effective risk-based approach.

Target Audience, Status and Content of the Guidance:

This guidance is presented in a way that is focused and relevant for casinos. The roles and therefore risks of the different DNFBP sectors are usually separate. However, in some business areas, there are inter-relationships between different DNFBP sectors, and between the DNFBPs and financial institutions. For example, some land-based casinos provide services similar to those provided by financial institutions, and Internet casinos tend to only make/receive payments using accounts held by financial institutions.

DNFBPs provide a range of services and activities that vastly differ, e.g. in their methods of delivery, and in the depth and duration of the relationships formed with customers, and the size of the operation. This Guidance is written at a high level to cater for the differing practices of casinos in different countries, and the different levels and forms of supervision that may apply. Each country and its national authorities should aim to establish a partnership with its casinos and other DNFBP sectors that will be mutually beneficial to combating money laundering and terrorist financing.

The primary target audience of this guidance is the casinos themselves, when they conduct activities that fall within the ambit of the FATF Recommendations.  All FATF references to "casinos" include Internet casinos.