The risks, preventative measures and operational actions from the perspective of an international betting operator 11 December 2012 David Norman Global Head of AML/MLRO CONFIDENTIAL and not for reproduction without prior written consent © of the author

PERCEPTION Internet gaming/betting is at risk from money laundering Why? – it is anonymous – non face to face business – funds are able to be moved globally very quickly – organised crime has a substantial stake in internet gaming companies – because of the volume, speed, anonymity, and international reach made possible by internet transactions (Brian Deese, deputy director of the National Economic Council, USA) CONFIDENTIAL and not for reproduction without prior written consent © of the author 2

THE EVIDENCE To support the perception there is no credible evidence to suggest that internet betting/gaming companies have been used as a vehicle to for money laundering To refute the perception there are no prosecutions world-wide where internet gaming companies have been used as a money laundering vehicle to launder the proceeds of crime every single action/key stroke an internet gaming customer makes is recorded and can be monitored three studies in recent years have concluded that internet gaming presents minimal money laundering risk – The threat of money-laundering and terrorist financing through the online gambling industry; a report prepared for the UK Remote Gaming Association by MHA Consulting, June – Money-Laundering Risks and E-Gaming: A European Overview and Assessment; by Michael Levi, Ph.D., D.Sc. (Econ.), Professor of Criminology, University of Cardiff, September – Can Internet Gambling Be Effectively Regulated? Managing the Risks; by Malcolm K. Sparrow John F. Kennedy School of Government, Harvard University, December 2009 CONFIDENTIAL and not for reproduction without prior written consent © of the author 3

BALANCED, RISK BASED, PROPORTIONATE CONFIDENTIAL and not for reproduction without prior written consent © of the author 4

SPORTING INTEGRITY & MONEY LAUNDERING Ability to Follow the money. Every transaction is recorded. Is there a reasonable explanation for the betting or is there any reason to be suspicious? Detailed Investigation of suspect betting and accounts. Monitoring betting markets and events in real-time at account level. Action taken against suspect accounts; suspension of account and freezing of winnings. CONFIDENTIAL and not for reproduction without prior written consent © of the author 5

DEFINING INTERNET BETTING/GAMING CountryInterpretationCDDRecord Keeping Denmark Casinos Internet Casinos/Betting Within 1 month of registration not to exceed DKK10,000 until CDD 5 years France Online poker game operators. Groups, clubs and companies organising games of chance, lotteries, sports or horse race betting. On registration within 30 days.5 years Italy Casinos, gambling and betting parlours. Online betting operators Cumulative deposits in excess1,000 (before) 10 years MaltaCasinos/Internet Casinos/Remote Gaming Regulations Risk Based? ASAP 5 years Spain Casinos Persons responsible for the management, operation and marketing of lotteries or other gambling activities in respect of prize payment transactions. Within 30 days of registration.10 years UKCasinos/Internet Casinos. Exchange of chips in excess of2,000 on daily basis 5 years GibraltarAll forms of remote gambling.On deposit 60 days5 years CONFIDENTIAL and not for reproduction without prior written consent © of the author 6

CONFIDENTIAL and not for reproduction without prior written consent © of the author David Norman Global Head of AML/MLRO