Financial Crime World

Gibraltar Gaming Regulator Highlights Medium Risk in Remote Gambling Sector

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The Gibraltar Gaming Regulator (GGC) has released a report highlighting several areas of medium risk within the remote gambling sector. The report identifies concerns around false documentation, customers on international sanctions lists, and peer-to-peer gaming.

Higher Risk Under Proceeds of Crime Act

According to the report, the non-face-to-face nature of remote gambling is recognized as a higher risk under the Proceeds of Crime Act (POCA). However, the GGC notes that many operators have implemented robust systems to mitigate these risks.

Key Concerns

  • False documentation
  • Customers on international sanctions lists
  • Peer-to-peer gaming

Importance of Due Diligence

The report emphasizes the importance of due diligence in respect of source of funds and wealth, as well as ongoing transactional monitoring to reduce the likelihood of criminal activity.

Internal Control Vulnerabilities


In terms of internal control vulnerabilities, the report identifies non-implementation of relevant legislation (POCA) and guidance from the supervisor (AML Code) as a medium risk. The GGC notes that while B2B Licence Holders are not exposed to the same risks as customer-facing operators, they are nevertheless under an obligation to monitor customer behavior on their platforms.

E-Wallets and Pre-Paid Cards


The report also highlights concerns around e-wallets masking the origin of funds and pre-paid cards (cash-funded) masking the origin of funds. The GGC emphasizes the importance of due diligence in respect of source of funds and wealth, as well as ongoing transactional monitoring to reduce the likelihood of criminal activity.

GGC’s Response

In response to these risks, the GGC has implemented several measures to mitigate them, including:

  • Requiring operators to present due diligence material and receive formal approval before engaging in business
  • Monitoring operator behavior closely and taking action against those that fail to comply with its regulations

Full Report Available


The full report can be found on the GGC’s website at [insert link].