Ray Wilson and his team have recently returned from a spell of compliance health checks in Malta, where several of their operator partners have been put on alert from the regulator that they are about to receive compliance assessments.
Regardless of how good you think your process or policies may be, or how knowledgeable your employees are, receiving notification of an upcoming regulatory assessment is a daunting time for operators.
It is understandable that a sense of uncertainty and in some cases fear kicks in, given all the enforcement action we have witnessed.
AMLGS works with regulators as well as operators to advise on what is expected and how they can reach the standards expected of them. But AMLGS stresses that it does not sit on the fence and is perfectly clear on their view that guidance, messages and regulation needs to be more transparent.
Wilson, AMLGS director, whose company is regularly called in to deliver the advice needed across government and to UK and MGA licence holders, said: “The operators we work with are all trying to improve and ensure their compliance.
“The reputation and future of our industry is at stake”
“One operator we are currently engaged with has been given their date for an assessment, we are helping them prepare the necessary documents and conducting a thorough review, because it is far better that we find gaps or vulnerabilities in their processes and help to repair them, than waiting for the regulator.”
Before going on to explain that part of the AMLGS operation is helping operators achieve and demonstrate good compliance: “There are many operators out there doing their best to repair the reputational damage of the industry, this is no longer about reputational damage for individual operators.
“Every time an operator fails, in the eyes of the public, we have all failed. We have a duty as an industry to protect consumers, and it is a duty that we take very seriously. The operators we work with share the same passion as us and we are determined to encourage more operators to do the same.
“The industry is very reactive in its approach to both AML and responsible gambling, it is a tough battle to change this embedded mindset and move to be a more proactive industry. I am not just referring to operators but the regulator also.
“We strongly believe that the guidance and regulation is not fit for purpose and in many ways can be held partially responsible for the consistent failings.”
In the constant battle to avoid regulatory enforcement action, gambling operators call upon the services of AMLGS for guidance, training and external reviews to keep them from the teeth of the regulator. Since November 2018 they have seen a significant rise in the uptake of both the compliance health check and training services.
“It is a tough battle for operators because they truly are left in a position of uncertainty as to what exactly they need to do”
The Health Check in particular has become one of their key services, one of the important aspects included is the mock regulatory assessment which creates a simulated environment to best prepare operators for regulatory reviews. Not only this, but it comes as no surprise that their forum and training workshop style events have seen a huge surge in demand from regulatory compliance professionals.
The last event was opened by Wes Himes, director of the RGA, with Malta hosting the next on September 25-26 and will contain key sessions delivered by the MGA.
Wilson added: “When we begin working with new operators the challenge is often the fact that they are simply unsure of what they need to do to satisfy the constantly changing requirements of the regulator.
“If it was as simple as following legislation, then I believe all operators would be in a position to achieve this quite easily…but this is not the case. Operators are not just expected to comply with their licence objectives, but they are expected to interpret what these requirements are because there simply is not enough clear, thorough and consistent information for operators.
“It is a tough battle for operators because they truly are left in a position of uncertainty as to what exactly they need to do to be compliant. We help operators and provide them the assurances they need in meeting their obligations, we want to protect them from enforcement action and reputational damage whilst safeguarding legitimate and vulnerable customers.
“There are many operators out there doing their best to repair the reputational damage of the industry”
“As I said before, the reputation and future of our industry is at stake. Of course we have some operators who clearly disregard the information that is available, and they are doing the industry no favours.
“I won’t hold back on my stance that any operator that demonstrates they have completely breached their obligations to reach commercial success at the cost of damaging people’s lives, and putting customers at harm and facilitating financial crime, should have their licences removed.”
The upcoming event in Malta has had great interest and places are still currently available, with it set to be followed by a free Compliance Health Check event in October and a further busy 12 months ahead.