Prevention of money laundering and terrorist financing in agent activities 

Traders who can identify risks related to money laundering and terrorist financing in their own operations or who can be assumed to be exploited for these purposes are in a key position in the fight against money laundering. About half of Veikkaus Oy's gambling takes place through the agent network, so the agents play a central role in the sale and distribution of gambling. 

Due to their central role, the agents have a good chance of detecting unusual customer behavior or deviant gambling. The Money Laundering Act also directly obliges agents to identify the customer and to report suspicious transactions. Therefore, agents play an essential role in the fight against money laundering.  

What should agents do pursuant to the Money Laundering Act?

As an agent or a representative of an agent, you must always identify the customer and verify the identity of the customer if:

• the customer spends at least 2,000 euros on gambling 
• the customer redeems at least 2,000 euros in profits
• you suspect the occurrence of suspicious business activity in the situation, or you suspect that the funds included in the business transaction are used for financing of terrorism or an attempt to do so, which is a punishable offence

The pecuniary amounts mentioned above may consist of one payment or several interlinked payments, totaling at least EUR 2,000 euros. 

The obligation to identify the customer is absolute and there are no exceptions.  Thus, for example, even a previously known customer must be identified and their identity must always be verified in the situations mentioned above.

As an agent, you have an obligation to make a suspicious transaction report if: 

• you detect suspicious business activity
• you suspect financing of terrorism.

Suspicious business activity means a transaction that deviates from the customer's usual activity or is atypical for the activity. Therefore, what is atypical depends on the customer or the situation. If you detect an unusual transaction, find out the reason for the transaction. If the transaction appears suspicious even after the clarification received, or if you do not receive any clarification, report the incident immediately to the Money Laundering Clearing House of Finland. As an agent, you can also submit a report through Veikkaus Oy. 

Suspicious transactions must always be refused. Remember to submit a report also if a fact that makes the transaction suspicious is subsequently discovered. The report of suspicious transaction must therefore be made, regardless of whether the transaction has been executed, suspended or refused. 

However, it is important that you do not disclose the making of the report or the investigation to the person who is the subject of the report or to any other person.