ECA AML and Compliance Workshop 2024

Welcome by the host
Guido Berghmans, General Manager Casino 2000

Presentation of the agenda - short introductory round by all participants

• ECA letter to the EU Commission regarding the 4^th SNRA.
• ECA meeting with Europol.
• New ECA position paper on AML.
• Size of the illegal gambling market in the EU.

The latest Brussels developments regarding the upcoming EU AML Regulation.
Presentation by Beata Guzik – Lawyer, vlaemminck.law, Brussels

Bio: Beata Guzik is Director EU Public Affairs at VLAEMMINCK.law. She has been working on gambling questions (especially RG & CSRD/CSDD, legal aspects of lotteries, betting & gambling marketing and advertising, AML & digital policy matters & innovation) in the EU and in Africa.

Teaser: In 2020, the European Commission has set to develop a comprehensive Union policy on preventing money laundering and terrorist financing. As the legislative package on Anti-Money Laundering / Combatting the Financing of Terrorism (AML/CFT) approaches its entry into force Ms. Beata Guzik will present on its impact on the gaming Industry.

Questions: 
This ammendment to the AML package was apperently not accepted ?: “Member States shall require payment service providers as defined in Article 4(11) of Directive (EU) 2015/2366 to ensure that they do not carry out transactions for gambling service providers which do not possess a licence in the Union.”

AMLA will promote the development and use of European digital wallets (EU Wallets). This, together with the €10,000 limit for cash transactions, will result in changes in the way casinos pay out credits and winnings.

Presentation Representatives of the Ministry of Justice, Luxembourg

Bio: Catherine Dion-Bourin leads Luxembourg’s fight against money laundering and terrorist financing. A director at the Ministry of Justice, she ensures rigorous international compliance thanks to her extensive experience and doctorate in European law.

Antton Madinabeitia is an attaché at the Ministry of Justice in Luxembourg. He works in the Directorate for Combating Money Laundering and Terrorist Financing, where he is responsible for risk assessments.

Teaser: tbd

Presentation Representative of Europol

Bio: Tomás Dominguez joined the Spanish Civil Guard in 1993. He has been working in intellectual property crime since 2015, first in the Department of Intelligence and Criminal Coordination of Financial Crimes and then in the Tax and Border Command as the person responsible for enforcing customs laws and regulations both at customs and borders and in the internal market.

In 2021, he joined Europol as a criminal intelligence analyst.

Teaser: tbd

Questions:
How does Europol evaluate the risk of infiltration or ownership by organised crime groups for slot machines outside of casinos?

EU AML regulations for casinos are currently too generic. We believe that increased collaboration between regulatory institutions and casinos is essential to develop more specific and effective guidelines that protect our business interests without imposing unnecessary burdens. How could this best be achieved?

In our opinion, the regulations issued by AMLA should be the same for all EU countries, i.e. they should not offer the possibility of being reinforced by individual countries. Does Europol see it the same way?

Preventing illegal gambling is the biggest challenge for us in the fight against money laundering and the prevention of gambling addiction and its social consequences. For over 20 years, Europe has been unable to achieve a regulated situation. How can illegal gambling finally be brought to an end?

Group photo shoot

Exchange among ECA members - Country-Specific Updates

We would like to cover the following topics. Please suggest further topics.
It would be good if you could provide presentations or content on the individual topics and generally inform us about the situation in your country.
Presentation Mike Meijer, Holland Casino

Next FATF Country Evaluations
Belgium (April 2025)
Italy and Austria (August 2025)

FATF Grey List Additions
Croatia and Monaco: Consequences for this countries and the casinos?

Holland Casino Case
In 2019, the Dutch Gaming Authority (KSA) flagged Holland Casino for AML failings. The casino then improved its procedures by enhancing player behavior monitoring.

Risk Assessments
SNRA & NRA: Special occurrences and updates

Business Relationships
Current status of the definition

“Unhealthy” GGR
We are seeing efforts in some countries to move away from ‘unhealthy’ GGR (France, Sweden...). This will have a positive impact on the image of licensed gaming companies.

De-risking Challenges
Issues faced by casinos in opening and maintaining bank accounts

AML Measures
New regulations and procedures
Recent fines for AML breaches
Technology and Tools

OSINT tools
Assessing higher-risk customers from credible sources
Presentation of a practical application

AI and AML
AI applications in the casino/gambling sector
Current uses of AI for AML in other sectors
Potential applications in casinos

Regulatory Compliance
Checks on senior management and beneficial owners: Recent changes

Illegal gambling
Current trends and measures

Taxes on gambling are being increased
An economic crisis is looming. States are heavily in debt.
As a consequence, taxes are being increased, including on gambling: in the Netherlands, France, Great Britain...
This drives consumers to illegal providers.

Training and Awareness
Best practices and new initiatives

Payment Innovations
Cashless gambling, player cards and e-wallets: Implementation plans

External Audits and Reviews
AML audits and reviews by consultancies

Affordability Checks
Concept and implementation

Addiction, Crime and AML
Exploring the link between addiction, crime and AML

Source of Wealth/Source of Funds (SOW/SOF)
We now have tools for KYC and the registration of financial transactions.
Challenges in verifying the legality of funds and affordability remain 

AML and Cybersecurity
The connection between cybercrime and money laundering

End of day one of the AML workshop
Get together and networking.

Dinner & networking at the Purple Lounge
Optional casino tour for first-time participants.

Discussion of AML topics (continued)

Presentation AMLIS (Casino 2000)
AML Intelligence System
Management of all relevant AML data und documents.
Automation of financial analyses of individual players.
Integration of the gambling protection programme.

Roundup of the findings of the workshop

Closing Remarks
Summary of key points
Next steps and follow-up actions

Agreement on the 2025 workshop dates – closing of the workshop