Update to Risk Assessment of Money Laundering and Terrorist Financing
The Gambling Administration of the National Police Board of Finland supervises to ensure that Veikkaus Oy and its agents comply with the Anti-Money Laundering Act, under which the supervisory authorities must have an up-to-date risk assessment of the prevention of money laundering and terrorist financing.
The risk assessment is the supervisory authority's view of the factors and events that threaten gambling activities with regard to money laundering and terrorist financing. The risk assessment identifies the most likely and significant money laundering risks concerning gambling and suggests ways to mitigate them.
Abolition of anonymous gambling reduced the risk of money laundering
The National Police Board of Finland made technical updates to the general section of the risk assessment, and updated the risk assessment for agent and gaming locations, trotting tracks and special gaming rooms. The risks of money laundering can be considered to have been reduced in these channels by the introduction of mandatory identification, as anonymous gambling is practically non-existent. However, the risks have not disappeared completely, as misuse of authentication devices is possible. In addition, a risk has been identified that the customer will not be verified in situations with aggregate limits under the Anti-Money Laundering Act, i.e. where the customer's stake or redemption is €2,000 or more in single or interconnected payments. A risk has also been identified that suspicious transactions are not identified and reported. Training and awareness-raising of staff at agent/gaming locations/trotting tracks and in special gaming rooms are effective risk management tools.
The National Police Board prepared a new risk assessment on sanctions and freezing orders under the Anti-Money Laundering Act. The most significant risks identified relating to sanctions and freezing orders in the gambling sector are personal, systemic and customer risks. Finland currently has a legal gambling monopoly system, which means that only Veikkaus Oy can legally offer gambling. Veikkaus Oy's gambling customers can only be natural persons who have a Finnish social security number and are domiciled in Finland. Since this can be considered as having a mitigating effect on sanctions risk in Finnish gambling, the sanctions risk in gambling operations is not considered very likely at the moment. However, the consequences may be significant if the risk materialises, as the materialisation of the risk may imply the possibility of both money laundering and terrorist financing.