The Gambling Anti-Money Laundering Group (GAMLG) is a new body established by the Remote Gambling Association (RGA) and the Association of British Bookmakers (ABB). The GAMLG’s first chairman, Keith Bristow QPM, has excellent credentials as the retired Director-General of the UK National Crime Agency.
The bookies avoided being included in the 2nd EU money laundering directive, contrary to the recommendation of Sir Alan Budd in his Gambling Review Report in 2001, and also got out of being included in the 3rd directive. They are also now fighting to be excluded from the 4th directive which would require ID verification for a gambler staking over £1,500 in one day in one venue.
One misleading angle the bookies have used is to claim that when someone comes to the counter just before a race and wants to bet £2,000, they would not be able to accept the bet if it was from an unknown customer. But the reality today is that bets of that size, just before the off from
unknown gamblers, are almost certain to be refused anyway, so this is not an argument based in reality.
The bookies’ remote online internet gambling sites are significant players in the RGA, so it is easy to see that GAMLG is bookie driven. But how many RGA members, including bookies, have obtained revenue from jurisdictions where governments have stated this was illegal? Does the willingness of site operators, software providers and affiliates to engage in such activity equate to a conspiracy to money launder the proceeds of crime?
Jenny Williams, previously of the Gambling Commission, spoke recently on this subject at the recent ICE Conference. She stated that: "We do not want to license operators that were willfully flouting laws in other jurisdictions,” and if they were then, "they'd be asked if it was true and if so they'd be told to stop". Clearly "flouting the law" is both evidence of immoral and unethical practice, and grounds for denial of gambling licensing suitability.
However, a gambling addict "flouting the law" and obtaining illegal funds to feed their addiction may end up facing incarceration, particularly if in a "position of trust". The incarceration cost is a burden on society as a whole, but gambling providers are entitled to retain illegal funds lost by addicts. Due to a lack of adequate treatment facilities, with minimal residential care options, only one dedicated NHS clinic, and poor GP awareness of appropriate cognitive behavioural therapy, there is often no treatment to ameliorate recidivism and prevent future incarceration.
Contrast this with gambling operators "flouting the law". The Gambling Commission simply asks them nicely to stop! It is to be hoped that Mr Bristow, with his National Crime Agency experience, will require a far higher level of legal compliance from the gambling operators that he will be representing, than the Gambling Commission has so far required.
One very relevant aspect is the
unreported crimes in betting shops of damage to FOBTs and premises. How much of this unreported crime is committed by persons who are gambling with the proceeds of crime? How much of this unreported crime is by money launders using FOBTs who fall into the trap of gambling on them, rather than just washing the cash at a nominal cost?
The pattern of money laundering on FOBT roulette is very easy to detect. Why has there not been any research into the FOBT data that was collated by the Responsible Gambling Trust researchers in order to assess FOBT money laundering?
When DCMS published the Evaluation of the £50 threshold measure why did it omit a money laundering analysis? In order to stake above £50 every 20 seconds the new measure requires an ID provision or staff interaction. However, the vast majority of gamblers that used to stake from £50 to £100 per spin preferred to remain anonymous, rather than provide ID to get a loyalty card. Consequently, stakes over £50 decreased by over 67% whilst stakes in the £40 to £50 range increased by around 315%!
Whilst
local betting shop money launderingmight seem trivial compared to international white-collar activity, the local social impact can be far more devastating. The cash black economy includes the drug trade and the sex trade. Easy high street money laundering makes those trades more viable. But when cash criminals become FOBT addicts, the downward spiral of crime and abuse really kicks in, whilst the bookies’ FOBT profits increase.
One way to really reduce the incidence of FOBT money laundering would be to reduce the maximum stake per spin from £100 to £2. This measure is supported by politicians from all parties, some national newspapers, the Local Government Association and around 100 local authorities that are concerned about FOBTs and associated crime. It is also the objective of the
STOP the FOBTs campaign.
The bookies must not be allowed to get away with using tools such as GAMLG and the Senet Group to protect their profits and prolong harm to society and individuals by delaying the inevitable FOBT stake reduction.