The Player ID’s impact on land-based betting operators and their AML obligations
This article is a continuation of the article "Player ID requirements for gambling at physical retailers" from 25 September 2023.
On 1 October 2023, it became a requirement for land-based betting operators to identify all customers before bets can be purchased from a physical retailer. In this connection, customers are issued a Player ID to which an account is linked.
The introduction of the Player ID and the associated account impacts the gambling operators' business model and the gambling operators must therefore assess whether the new business model means that the gambling operators' inherent risk of being misused for money laundering and terrorist financing has changed.
As a rule, a risk assessment must be reassessed at least once a year or otherwise in connection with significant changes in the business model. The introduction of the Player ID may therefore cause the gambling operators to update their risk assessment and, on that basis, update their policies, business procedures and controls.
Gambling operators must, for example, consider the extent to which the Player ID can be misused and then assess the impact this has on their inherent risk of being misused for money laundering and terrorist financing. The gambling operators must then assess which limiting measures must be implemented in order to limit the risk of, for example, misuse of the Player ID.
For example, the gambling operators must also consider the risks that may be associated with customers being provided with an account. For example, it could be the fact that the customers' winnings are paid out to the account. In the same way, the gambling operators must subsequently assess which measures must be taken to limit the identified risks that may be associated with the account.