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Prevention of money laundering and terrorist financing in gambling

Gambling is an economic activity and consequently also one potential area that can be used for money laundering and terrorist financing. Money laundering refers to activities where the aim is to conceal the source of the proceeds of criminal activity and to make them appear legitimate. Terrorist financing is the provision, acquisition or collection of funds from legal or illegal origins for terrorist purposes.

The Act on Preventing Money Laundering and Terrorist Financing (444/2017) has a broad scope of application. In mainland Finland, it applies both to the gambling company Veikkaus Oy and its agents, i.e. the businesses and organisations that supply its games.

Under the Act, Veikkaus Oy and its agents are obliged, subject to certain conditions, to:

  • identify their customers
  • verify their customers’ identity
  • monitor any unusual patterns of transactions in their operations
  • submit money laundering reports on suspicious transactions to the Financial Intelligence Unit of the National Bureau of Investigation.

Veikkaus Oy must also draw up a risk assessment to identify and assess the risks of money laundering and terrorist financing.

The National Police Board supervises that the gambling company Veikkaus Oy and its agents comply with the Act on Preventing Money Laundering and Terrorist Financing. In practice, the Gambling Administration at the National Police Board carries out the supervisory duties. 

According to the Act, the National Police Board must ensure that the gambling company fulfil the obligations laid down for it in the Act and implement all necessary measures. The National Police Board is also obliged to report to the Financial Intelligence Unit any suspicious transactions uncovered in connection with supervision or other duties it performs, or if it suspects terrorist financing. However, the investigation of suspected offenses is the responsibility of the police.

What is a supervisor-specific risk assessment under the Money Laundering Act and why has one been published?

The National Police Board has published an assessment of the risks of money laundering and terrorist financing in gambling operations in mainland Finland.

The risk assessment is the supervisory authority's view of the threats and events affecting gambling activities with regard to money laundering and terrorist financing.

The risk assessment has identified the most likely and significant money laundering risks to gambling and presents ways to reduce them.

The risk assessment enables the prevention of money laundering and terrorist financing to be targeted, inter alia, at those services and products for which the risks have been identified as being the most significant. In supervisory activities, such targeting of supervision is referred to as risk-based supervision.

The risk assessment also serves as a tool for the gaming company to assess whether all the risks presented in the supervisory authority's risk assessment have been considered in gambling operations and how the risks and control measures have been assessed by the supervisor.

The risk assessment consists of two sections, a general section and a summary. The general section of the risk assessment presents the purpose and objective of the assessment and outlines the specific features of gambling in mainland Finland. In addition, the document defines the sources used in the evaluation as well as the method used. The summary highlights the most significant risks identified in the risk assessment.

General section of the supervisor-specific risk assessment pursuant to the Anti-money Laundering Act

Summary of the supervisor-specific risk assessment pursuant to the Anti-Money Laundering Act

Riskiarvio - infolaatikko EN

Assessment of risks in slot machine gambling published

The National Police Board has published an assessment of the risks of money laundering and terrorist financing in slot machines in gambling operations in mainland Finland. This summary presents the most significant slot machine gambling-related money laundering risks as presented in the risk assessment conducted by the National Police Board’s Gambling Administration.

Slot machines outside casinos, i.e. in gambling locations and specific game rooms, were included in the scope of the Anti-Money Laundering Act at the beginning of 2022. The money laundering risk of slot machines may be increased by factors including deficient/insufficient customer identification and verification of identity, slot machine features that enable the use of new payment methods, and the placement of slot machines. Risks may be reduced by developing more effective methods of identification and verification. Additionally, bet restrictions included in slot machines are an effective component of money laundering risk prevention.

This appendix to the supervisor’s risk assessment supplements the supervisor-specific risk assessment summary published pursuant to the Anti-Money Laundering Act on 29 January 2021. This appendix to the risk assessment should be examined with the general section of the supervisor-specific risk assessment published in 2021.

Summary of slot machine risk assessment in English