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Risk Assessment Report for Gibraltar
This report provides an overview of various risks associated with different sectors in Gibraltar, including bribery and corruption, remote gaming, sanctions, tobacco, terrorist targeting, and proximity to organized crime.
Bribery & Corruption: A Major Risk
Primary Risk Event
- Businesses may obtain contracts based on corrupt practices.
Contributing Factors
- Lack of awareness about relevant laws and regulations (Crimes Act, OECD Convention, UK Bribery Act).
- Proximity to countries with common bribery practices.
Threats or Vulnerabilities
- Increased likelihood due to the proximity to countries with corrupt practices.
Remote Gaming Sector: A Low-Value/High-Risk Industry
Primary Risk Event
- Online gaming accounts may be used for money laundering or terrorist financing.
Contributing Factors
- Gibraltar’s large online gaming market and low-value/high-volume transactions.
Threats or Vulnerabilities
- Low-value ML/TF risks due to Customer Due Diligence measures in place.
Sanctions: A Risk of Non-Compliance
Primary Risk Event
- Gibraltar transactions may be used to circumvent international sanctions.
Contributing Factors
- Lack of centralized local list of applicable sanctions and local awareness.
Threats or Vulnerabilities
- Increased likelihood due to the lack of awareness about sanctions.
Tobacco: A Cash-Based Industry with ML Risks
Primary Risk Event
- Tobacco sales may present an attractive target for money laundering.
Contributing Factors
- Cash-only environment in tobacco retailing and wholesale businesses.
- Currency conversion issues (Sterling zone).
Threats or Vulnerabilities
- Possible use of licensed retail operations to obfuscate cash deposits.
Terrorist Target: A Growing Concern
Primary Risk Event
- Terrorist attack on Gibraltar due to its connections with the UK and proximity to North Africa.
Contributing Factors
- Rise in Islamist extremism in North Africa and desire for retaliation against Western countries.
- Established connection between Gibraltar and North Africa (Morocco).
Threats or Vulnerabilities
- Increased likelihood due to the rise in Islamist extremism and established connection.
Proximity of Organised Crime: A Significant Risk
Primary Risk Event
- Proximity of organized crime gangs operating in neighboring countries who may perceive Gibraltar as an opportunity to launder their proceeds.
Contributing Factors
- Sophistication and mobility of criminals.
- Poor economic climate and unemployment rates in neighboring regions.
Threats or Vulnerabilities
- Increased likelihood due to the poor economic climate and unemployment rates.
Conclusion
This report highlights various risks across different sectors, with some being considered higher than others. The report also identifies contributing factors and threats or vulnerabilities that increase the likelihood of each risk event occurring.