The Netherlands Gaming Authority is adapting the AMLD guidelines for online gambling games

The Gaming Authority has tightened up the AMLD guidelines in connection with the entry into force of the Remote Games of Chance Act (in Dutch: Koa) on 1 April 2021. The Anti-Money Laundering Directive (hereinafter: AMLD) has been amended due to the entry into force of the new Act. Koa are also going to apply to providers of online gambling games.

Until recently, the provisions contained in the AMLD only applied to physical locations of games of chance of the Holland Casino. Due to the legalization of online games of chance, the Gaming Authority has amended the AMLD guidelines to provide online providers with handles in complying with the AMLD. The first version has been submitted for consultation at various parties.

As of April 1, permits can be applied for for online games of chance. If the license is granted, one falls under the supervision of the Gaming Authority. Since 2016, the Gaming Authority has been charged with enforcing the AMLD for their target group. The purpose of the AMLD is to prevent the use of the financial system for money laundering and terrorist financing. The prevention of money laundering is of great social importance for an effective fight against serious forms of crime. The government employs various professions and branches as "gatekeepers" by means of the AMLD. For example, these professions and industries report high-profile transactions to the authorities who may then decide to investigate the individual or company in question.

With online gambling providers, it is particularly important to keep an eye on unusual transactions and the turnover rate of the transactions. The AMLD is applied more strictly in online sports gambling games because there is also a chance of match fixing. A special unit has been set up within the Gaming Authority that monitors match fixing: Sports Betting Intelligence Unit, or SBIU. The SBIU can report possible match fixing in games of chance. Holders of a license for remote games of chance must report this to the SBIU. Land-based sports betting does not have to comply with the obligations of the AMLD, but does have an obligation to report to the SBIU.

A games of chance provider conducts a customer due diligence in the following cases:

• When entering into a business relationship; The Gaming Authority assumes that a games of chance provider always enters into a business relationship with its players. A customer due diligence must therefore always be carried out, but only a registration of a player is not a business relationship. Before making a payment and participating in a game of chance, the provider must complete a customer due diligence. 1
• If there are indications that the player is involved in money laundering;
• If it doubts the correctness, completeness or topicality of previously obtained data from the player;
• If the risk of involvement of an existing player in money laundering gives cause to do so;
• If, given a player's state of residence, there is an increased risk of money laundering.

The customer due diligence consists of four steps. First, the identity is established and confirmed on the basis of an identity document. Subsequently, the games of chance provider must make a risk assessment of the player. The games of chance authority provides a number of risk factor-increasing. You perform a simplified, standard or enhanced customer due diligence on the basis of your risk assessment. The third step in customer due diligence is to continuously monitor the business relationship and the transactions that take place during that relationship. As a fourth step, if necessary, is an investigation into the source of the funds. You do this at an increased risk.