Our approach to AML and CTF
Entain operates in a number of different jurisdictions, which often have differing Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) requirements. This public document therefore details our approach to AML & CTF generally across the Group and common steps we apply as part of our commitment to work to keep crime out of gambling.
All gambling operators, whether remote or non-remote, and wherever regulated have a responsibility to work towards keeping financial crime out of gambling. Legislation, regulation and guidance in each applicable jurisdiction place an obligation on operators to be alert to customer attempts to gamble with the proceeds of crime. This includes both the act of using criminal proceeds to fund gambling, or by extension, attempting to obtain legitimate or ‘clean’ money in return.
A risk-based approach is required, with risk-based rules and criteria to proportionately manage Money Laundering (“ML”) and Terrorist Financing (“TF”) risk.
Entain Group Approach
The Entain Group applies a risk-based approach to focus effort where it is most needed and will have the most impact. Our Code of Conduct, similarly published on our corporate website, underlines senior management commitment in this area, and the standards expected by employees.
This approach involves a number of steps to assess the most proportionate way to manage and mitigate the ML and TF risks faced by the Group:
- Identifying the ML and TF risks relevant to our operations;
- Designing and implementing policies, procedures, and processes to manage and mitigate the risks;
- Monitoring and improving the effective operation of these controls;
- Recording what has been done, and why.
The Entain approach to ML and TF is outlined as part of a four-stage approach for both our UK and International operations. This includes:
- The Entain Group Anti-Money Laundering and Counter Terrorist Financing (AML/CTF) Policy which outlines at a high level internally our commitment to put in place robust measures to ensure that efforts to launder the proceeds of crime are prevented or, where efforts cannot be prevented, to report incidents in accordance with our legal obligations.
- Our Risk Assessment, which is an ongoing process with regard to how the company could be used for ML/TF. Our AML risk assessments relate to our Retail and Digital platforms. Assessments provide the basis for designing and upholding processes and procedures to highlight potential risks for attention. The risk assessment takes account of the respective risk assessments made available by regulators or supervisors.
- AML Operations Guidance for internal stakeholders, highlighting our AML organisation, legal obligations, suspicious activity reporting protocols, and a summary of the procedures put in place to detect and mitigate ML & TF risks.
- AML Processes which describe the practical processes and systems specific to each jurisdiction and division to monitor customer activity for the purpose of identifying concerning or suspicious activity and conducting further investigations.
Money laundering is a serious criminal offence and could result in fines, imprisonment and the potential loss of our gambling licence.
Employees can be found guilty of money laundering if they:
- assist in money laundering;
- know or suspect that somebody is gambling with the proceeds of crime and don’t report it;
- tip off somebody that they are under investigation;
- do anything to ‘prejudice an investigation’, which can include falsifying information.
How we detect and prevent money laundering
Entain operates in a number of different jurisdictions which have differing and specific requirements. The below summarises common themes:
Knowing Our Customers
Customer Due Diligence & Ongoing Monitoring
Checking our customers’ identity and understanding where their funds come from as and where appropriate.
For customers, for example, utilising our services from Great Britain we have systems in place to meet requirements to verify the identity, address, and date of birth of customers in our regulated online gambling business prior to gambling. Customer identity is verified further where required by UK Money Laundering Regulations at certain thresholds to satisfactorily reduce the potential specific risk posed by non-face-to-face business.
Verification of customer identity involves verifying the customer information against documents or information (i.e. from 3rd party verification services) obtained from a reliable and independent source. Our Know Your Customer teams are responsible for this process.
Our UK retail business seeks to establish customer identity on a risk-based approach in line with monitoring processes and regulatory guidance.
Ongoing monitoring involves our AML teams reviewing customer activity against prevailing procedures. This includes, for example, proactive risk-based customer spend threshold reviews, reviews following internal suspicious activity reports, and reactively investigating adverse media or law enforcement alerts. Further enhanced due diligence, including source of funds and wealth are considered as appropriate in this framework, including in respect of PEPs. The frequency of ongoing customer review is determined by the framework and on a risk-based approach and managed through relevant case management systems.
Our Risk Operations function maintain rule sets to prevent and/or flag potential account risks in respect of geo-location, payment methods, and multiple accounts.
Each country where we operate may have different requirements, and these are covered in the appropriate section of our process documentation.
Adverse Information Checks - PEPs, Sanctions & Terrorism
Formal searches to identify whether customers are subject to sanctions, are Politically Exposed Persons, or linked to terrorism
Entain’s active customer base is frequently screened using third party software in line with jurisdictional requirements.
The software compares the registered details of our customers against lists of PEPs, their relatives or close associates, sanctioned individuals and lists of known criminals.
This comparison produces potential matches that are reviewed to be confirmed or dismissed by our AML analysts.
Confirmed sanctions or terrorism links lead to the termination of customer relationships and MLRO reporting to the appropriate institution.
Senior Management sign off of higher risk customer relationships
Identified Politically Exposed Persons lead to further risk assessment and an appropriate level of due diligence based on that assessment; ongoing relationships require Group MLRO approval.
The MLRO retains a record of identified PEP customers, and ongoing monitoring is managed through prevailing case management systems.
Governance processes operate across the Entain Group, and in the UK, for example, includes MLRO sign off of decision making in respect of next steps for perceived potential higher risk customers.
Record Keeping of AML/CTF related documents
For the purpose of performing our AML & CTF obligations, Entain preserves documents and information as required by prevailing legislation and local requirements.
This comprises, for example, customer due diligence, ongoing monitoring and governance records as detailed above, including the reasons for decisions and actions taken from an AML and CTF perspective. Employee training records and internal periodic/annual reports are also retained in addition to records pertaining to internal and external suspicious activity reports.
The duration of retention of such data varies between jurisdictions, but in general the relevant data is kept for a minimum of five years, calculated from the date on which business relationships are terminated.
Ensuring employees are trained with regards to AML & CTF
All Entain employees regardless of seniority are required to undertake AML e-learning which includes a short assessment. This is refreshed on an annual basis, and includes background information on money laundering, potential offences, the role of colleagues in detecting potential risk triggers and escalating their detection, alongside case studies.
Where applicable (i.e. in the UK) specific internal Personal Management Licence (PML) training is also in place covering AML & CTF for senior management. This is supplemented by our AML Handbook Operations Guide.
Retail shop colleagues receive a specific AML E-Learning module on a yearly basis, and includes an in-built assessment. This is supplemented by Shop Operating Procedures documentation which outline the day to day tasks required to uphold AML.
AML teams are trained by existing analysts at induction, and all AML colleagues are required to be familiar with our AML Handbooks which detail day to day to processes. This is supplemented by process guides.
Face-to-face training is also conducted by AML managers with our AML analyst and customer management teams.
AML colleagues are further provided with relevant face-to-face 3rd party training where available and relevant in each jurisdiction. This includes, for example, our AML analysts covering our UK operations who undertake a specialist AML certificate in betting and gaming.
Senior AML Managers attend and participate in industry and regulatory workshops to keep knowledge up to date.
Entain is committed to ongoing independent evaluation of our risk assessments, procedures, and processes.
This is supplemented by the work of our internal audit and assurance functions.