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Gaming Regulation Update


Record Attendance at the 2015 Gaming Regulation Forum

The 3rd Annual Caribbean and Americas Gaming Regulation Forum in Miami, Florida welcomed the largest number of delegates so far, from the widest range of nations.

This years attendees included attorney generals, regulatory commissioners, financial intelligence units and directors of compliance and surveillance from:

Antigua Canada Mexico St Lucia
Aruba Curacao Panama Suriname
Bahamas          Dominican Republic Peru Trinidad & Tobago
Belize Guatemala Puerto Rico Turks & Caicos
Bermuda Guyana Sint Maarten USA
Brazil Jamaica St Kitts & Nevis       US Virgin Islands



Embassy Sponsors Mexican Anti-Money Laundering Programme
February 2014

  • International experts will lead capacity building programme for senior officials from Mexican government agencies.
  • The project is funded by the British Embassy in Mexico to support local initiatives to combat money laundering activities.

Mexico City, 28th February 2014 – Mexican authorities will next week attend an internationally-backed training programme on best practice techniques for combating money laundering.

Some 80 officials from a variety of Mexican government bodies will participate in the five-day programme, which will be held in Mexico City between 3rd and 7th March. The programme is the second of a two-stage capacity building initiative, funded by the UK Embassy, designed to assist Mexican government officials to implement effective anti-money laundering mechanisms in the country.

The overall programme objective is to help state officials to better identify potentially suspicious transactions and to prevent criminal funds from entering the country’s financial system. The main focus of this initiative will be developing transaction monitoring systems for lawyers, real estate agents, precious metals dealers, and other professions associated with higher levels of money laundering risk.

The programme also aims to help with the implementation of a ‘Risk Based Approach’ (RBA) to money laundering offences, under which the stringency of checks would vary according to the level of risk represented by a particular client. The implementation of the RBA is a key recommendation of the Financial Action Task Force, an international standards setting body for anti-money laundering strategies.

This capacity building programme will be led by Dr. Alejandro Montesdeoca-Broquetas, a senior expert of GovRisk. Dr Montesdeoca-Broquetas formerly served as Executive Secretary of the Financial Action Task Force of South America (GAFISUD) between 2005 and 2012, where he led a wide variety of money laundering training and evaluation programmes. Other GovRisk experts who will also participate in the training include: Juan Antonio Aliaga Méndez, a Spanish anti-money laundering expert who has served on the European Commission’s Banking Committee and the Financial Action Task Force, and Bernardo Mota, the deputy head of Brazil’s Financial Intelligence Unit.

This project will come at a highly opportune moment for Mexico. Mark Willcock, Programme Development Manager, reported that “the passing of the Federal Law for the Prevention and Detection of Operations Involving Illicit Resources in July last year has made a whole host of business sectors newly subject to enhanced money laundering checks. As such, this programme will provide vital assistance to the Financial Intelligence Unit and Tax Administrative Authority who are responsible for implementing these significant reforms”.

This initiative is financed as part of the UK Foreign and Commonwealth’s Prosperity Fund programme, which seeks to increase exports and investment, open markets, ensure access to resources and promote sustainable global growth.


Colombian Summit to Tackle Corruption in Public Infrastructure Projects
February 2014

  • High level event in February 2014 will discuss how best to prevent illicit activity occurring in infrastructure construction programmes.
  • Senior representatives from infrastructure, anti-corruption and procurement bodies in Peru, Mexico, Panama, Costa Rica and Chile will participate in the event.

Bogotá, 3rd December 2013 – In early 2014 Colombia will host a high-level regional summit with the aim of promoting transparency and good governance in public infrastructure projects.

Programme participants will include senior managers from infrastructure, anti-corruption and public procurement bodies in Colombia, Peru, Mexico, Costa Rica, Panama and Chile. The aim is for attendees to: share their experiences of tackling corruption, collusion and fraud in such projects; improve their understanding of international best practice guidelines from the OECD, Basel Institute on Governance, Inter-American Development Bank and others; and discuss how these techniques could be adapted and effectively implemented in the individual country contexts.

The event will also feature workshops led by Colombian experts including Luis Fernando Andrade, president of the National Infrastructure Agency (ANI) and Rafael Merchán, director of the Transparency Secretariat. These officials will primarily discuss Colombia’s experience of launching the High Level Reporting Mechanism (HLRM); an initiative which aims to facilitate, and assign higher priority to, private sector complaints of bribery solicitation during the procurement process. According to Merchán, “Colombia’s development of the HLRM, a pilot project of the OECD and the Basel Institute on Governance, has already produced results in the fight against corruption in public infrastructure projects. Our participation in this seminar will help us additionally refine the operation of the mechanism, and to discuss with our regional counterparts how they might replicate this tool in their own countries.”

According to the World Economic Forum, public procurement is the area of government activity most vulnerable to corruption and fraud. For infrastructure projects in particular, the vast size of the contracts, coupled with the opacity of the tender processes and limited levels of oversight of government officials, mean that such expenditure is highly vulnerable to illicit practices such as corruption, collusion and fraud. Recent high-profile scandals involving infrastructure projects in Bogotá, such as that relating to the Transmileno Calle 26 under former Mayor Samuel Moreno, demonstrate the risk in this regard. Local and international experts report the absence of, and need for, programmes such as this new initiative, which address the specific dynamics of infrastructure procurement challenges.

Next year’s programme is a joint initiative between the UK Embassy in Bogota and Colombia’s National Infrastructure Agency (ANI) and Transparency Secretariat. The initiative is financed as part of the UK Foreign and Commonwealth’s Prosperity Fund programme, which seeks to increase exports and investment, open markets, ensure access to resources and promote sustainable global growth. According to Lindsay Croisdale-Appleby, UK Ambassador to Colombia, “Inadequate infrastructure is one of the greatest barriers to allowing Latin American economies to realise their economic potential. By bringing together high-level officials in this area together with international infrastructure and procurement experts, we are confident that this programme will help ensure investments in infrastructure are spent effectively and transparently, and deliver maximum value for money”.


International Experts Assist Cuban Anti-Money Laundering Efforts
October 2013

Havana, 22nd October 2013 – In November Cuban government institutions will receive technical assistance from international experts on how to improve its anti-money laundering regime.

The programme, a joint initiative of British Embassy in Cuba, the International Governance and Risk Institute (GovRisk) and Cuba’s Central Bank, aims to help the country prepare for an upcoming evaluation by international financial examiners. The assessment, which will be carried out by 2015, will see experts from GAFISUD, the Latin America arm of the Financial Action Task Force (FATF), examine the extent to which the country complies with international guidelines on anti-money laundering and counter terrorist financing measures. A positive verdict by the assessors would boost efforts to attract foreign investment to the Mariel Bay special development zone by increasing external confidence in the integrity of financial systems.

The first of several phases of the programme will begin in Havana next month. During this stage, approximately 50 high level officials from Cuba’s Financial Intelligence Unit and other key institutions with a role in combatting money laundering will be trained in best practice techniques for complying with FATF standards. They will also be provided with guidance on how to implement a Risk-Based Approach to these offences, allowing the country’s financial institutions and other designated sectors to effectively assign compliance resources to the areas of highest risk.

Training will be led by GovRisk expert, Dr. Alejandro Montesdeoca Broquetas. In the months after the initial programme, the beneficiary institutions will replicate this course, under the guidance of Dr Montesdeoca Broquetas, within their own agencies. A total of approximately 500 officials are expected to be trained.

According to the programme organisers, this initiative will assist Cuban efforts to work itself off FATF’s ‘grey’ list of non-cooperative jurisdictions for money laundering and terrorist financing offences. GovRisk's own Mark Willcock reported “By training Cuban officials on how to comply with international guidelines on anti-money laundering this programme will improve its chances of gaining a positive review from FATF assessors. This will, in turn, make it cheaper and easier for the country to access trade finance and secure international investment”.

A representative from Cuba’s Financial Intelligence Unit added “we are extremely pleased to be collaborating with GovRisk and the UK Embassy to help address our anti-money laundering needs. This programme will provide a vitally important boost to our own efforts to prevent the entrance of illicit and criminal funds into the Cuban financial system”.

This initiative is financed as part of the UK Foreign and Commonwealth’s Prosperity Fund programme, which seeks to increase exports and investment, open markets, ensure access to resources and promote sustainable global growth.


Panama to Host International Forum on Combating Corruption in Procurement
July 2013

  • International experts will lead workshops on preventing collusion and corruption in public procurement processes.
  • Financial regulators, prosecutors and procurement officials will travel to Panama for the event between the 10th and 13th September.

Panama City, 22nd July 2013 – Panama will shortly play host to a regional forum to discuss techniques for tackling corruption and collusion in Latin American and Caribbean procurement.  

Topics under discussion will include how to overcome potential conflicts between anti-corruption and anti-collusion strategies; measuring the cost and impact of illicit activities on procurement processes; and making optimal use of latest technologies and international guidelines to detect and deter fraud, corruption and collusion in public contracting.

International bodies have repeatedly highlighted collusion and corruption as serious problems in Latin America and Caribbean procurement. Such activity serves to distort market mechanisms and has dramatically reduced the efficiency of public expenditure. By improving preventative strategies and enhancing enforcement capacity, experts report, governments throughout the region could secure substantial savings on their procurement expenditure.

Over 150 senior financial regulators, prosecutors, procurement practitioners and policy makers are anticipated to attend the forum, which will be held in Panama City from 10th to 13th September.

During four days, approximately 15 international experts will lead a series of workshops, seminars and presentations to examine key lessons from recent emblematic procurement fraud cases, discuss prevention and risk management strategies, and provide guidance on meeting procurement standards outlined in the United Nations Convention against Corruption of the OECD, World Bank and Inter-American Development Bank.

The conference, organised by UK consultancy firm the International Governance and Risk Institute (GovRisk), is a joint initiative of the UK Embassy in Panama, Panama’s Competition Commission (ACODECO), the Directorate of Government Procurement and Contracting (PanamaCompra), and the Regional Anti-Corruption Academy for Central America (ARAC), a body established by the United Nations Office on Drugs and Crime and the National Transparency and Freedom of Information Authority.
Eldis Sánchez, director of PanamaCompra and current president of the Inter-American Network for Government Procurement (RICG), added “we are extremely pleased to be collaborating with GovRisk and the UK Embassy to help address our procurement needs. This programme will provide a vitally important boost to the efforts of Panama and other countries to rectify inefficiencies in state purchasing processes”.
This initiative is financed as part of the UK Foreign and Commonwealth’s Prosperity Fund programme, which seeks to increase exports and investment, open markets, ensure access to resources and promote sustainable global growth. According to Matthew Phillips, Chargé d’Affaires at the UK Embassy, “transparency in public procurement is vitally important as it prevents corruption and stops resources from being diverted away from where they are most needed. The UK believes that bringing together state suppliers, procurement officers and the private sector to discuss the challenges they face in this area will be a key step towards reducing corruption and achieving sustainable growth”.


Seminar About Better Practices in Public Procurement in Santiago
UK Embassy Website, May 2013

British expert spoke at a Seminar organised by government agency ChileCompra to promote better practices in public procurement.

With the support of the British embassy in Santiago and the International Governance and Risk Institute (GovRisk), ChileCompra organised a Seminar on 15 May to promote better practices in public procurement and stop potential irregularities in the process carried out by Chilean authorities. During the seminar, the ChileCompra Observatory initiative was also launched with the purpose of reducing bureaucracy and improving the quality of public procurement in Chile.

Michael Kramer, an anti-corruption expert representing GovRisk and senior consultant of the World Bank spoke about how to prevent fraud in the public procurement process and related contracts, and what are the best strategies existing worldwide to prevent such irregularities.

At the event Russell Baker, Chargé d’Affaires at the British Embassy, said:

"The British government believe this is an important part of the agenda to advance economic reform in Chile. So we are very pleased to have financed the participation of Mike Kramer of the British organisation GovRisk. We also intend to continue our collaboration with ChileCompra and the Chilean government on the agenda of public procurement this year. And one of our plans is a training course on reducing bureaucracy, carried out by GovRisk, in August."


Risk of Money Laundering Grows With Economy
Cambodia Daily, March 2013

With Cambodia currently seen as a country where the laundering of illicit cash may be going undetected, an international expert on Monday warned that economic growth and more international trade could leave the country even more open to financial crime.

This month the U.S. government depicted Cambodia as vulnerable to money laundering, and on Monday, the National Bank of Cambodia’s Financial Intelligence Unit (FIU), law enforcement officials and private banks began a weeklong training program to address the problem.

The training—provided by the U.K.-based International Governance and Risk Institute, or GovRisk, and paid for by the British Embassy—is aimed at arming Cambodian authorities with the knowledge needed to stop the exploitation of the country’s light regulations on financial crime.

Gert Demmink, a former head of supervision at the Netherlands’ central bank and a consultant on financial crime for GovRisk, said it was impossible to reliably say how much money was laundered in any country. But, counter-intuitively, he said, Cambodia might not be a particularly attractive jurisdiction for criminals looking to launder money.

Money launderers “seek out new economies where they can safely hide their money, conceal their money…make sure that they will not lose due to high levels of corruption and make sure that they can utilize the formal financial [system],” Mr. Demmink said, speaking on the sidelines of the workshop.

He explained that money launderers are, in effect, investors, and may have in the past been put off Cambodia because of high corruption and political instability, which threaten the security of their money.

“Money launderers never take chances,” he said, adding that money launderers also looked to economies with higher gross domestic product where it is easier for unexplained amounts of cash to go unnoticed.

Still, with economic growth in Cambodia having reached more than 7 percent over the past two years, and the value of the country’s imports and exports rising fast, the risk of money laundering will increase, Mr. Demmink said.

“That will also attract attention by any criminals, money launderers, because, like I said, they are investors,” he said.

Mr. Demmink said that China—the source of more than a quarter of the total foreign direct investment in Cambodia—was one of the largest sources of money that criminals seek to launder.

Thus, with trade between China and Cambodia set to increase—the two governments have targeted annual trade between the two countries to reach $5 billion by 2017—there will be a greater need to monitor transactions for irregularities, he said.

“The question is: Can Cambodia cater for that, or is there going to be…unsupervised, unattended business?” he asked.

This week’s training follows findings last month by the Financial Action Task Force (FATF), an intergovernmental body that promotes policies to combat money laundering, that there are “deficiencies” in Cambodia’s approach to tackling money laundering. The FATF urged Cambodia to redouble efforts to criminalize money laundering and monitor financial flows.

Despite having passed a 2007 law on money laundering and terrorist financing, and in 2008 established the FIU, which is housed within the National Bank of Cambodia, few people have been prosecuted for laundering cash in Cambodia.

Neav Chanthana, deputy governor of the National Bank of Cambodia, said she hoped that the training would help Cambodia to comply with FATF’s recommendations, and said it was important the issue was addressed.

“Some people have a view that [money laundering] contributes to the economic development by attracting investors and thereby creating employment for the poor,” she said.

“But if we go deeply to its source, we will see that money laundered in the economy has its source from proceeds of offenses, especially proceeds from drug trading, corruption, human trafficking and so on.”

The U.S. State Department’s annual International Narcotics Control Strategy Report, published on March 1, in its section on financial crime in Cambodia, says the country had “significant money laundering vulnerability,” citing the cash-based dollarized economy, informal financial systems, porous borders and limited regulation.

“A weak judicial system and endemic corruption are additional factors negatively impacting enforcement,” the State Department said in the report. “Given the high level of corruption, [the government of Cambodia] also should require enhanced due diligence for domestic politically exposed persons,” the report adds, referring to high-ranking officials.

“Cash proceeds from crime are readily channeled into land, housing, luxury goods, and other forms of property without passing through the formal banking sector,” the report says, recommending that the government “increase the capability of the nascent and understaffed FIU.”

The State Department also said, “Casinos along the borders with Thailand and Vietnam also are another potential avenue to convert ill-gotten cash.”

While NagaWorld holds an exclusive license to operate as a casino in Phnom Penh, gaming venues catering to gamblers from neighboring countries increasingly populate border towns.

“Casinos indeed can be perfect money laundering havens. For the casino owners themselves, but also for the customers,” said Mr. Demmink.

“If I wanted to provide proof of my recent wealth I might say, ‘I set up a casino and it’s thriving.”

“The question is: Are there any customers?” he said, adding that strict oversight was needed on casino operations to ensure that they were not being used to launder the proceeds of crime.


Regional Latin American and Caribbean Forum on Financial Crimes
United Nations Office on Drugs and Crime, January 2013

From the 14th to the 18th of January 2013, the first Latin-American and Caribbean forum on Prevention of Financial Crimes was held in Panama, with the support of the British Embassy in Panama and the International Governance and Risk Institute (GovRisk), program which belongs to the State Department of the United Kingdom.

The Forum assembled more than 180 experts coming from 25 countries of the Latin American region, between which there were prosecutors who are members of the Network of Prosecutors against Organized Crime (REFCO), who besides debating topics related to the prevention, examined the management of the risk of the corruption and a series of directives to be delivered on how to improve the procedures for the fulfilment, underlining the need to fulfilling the parameters of transparency, diligence and fulfilment of the aims to be able to face to the threat. 



UK diplomat urges Philippines to amend anti-money-laundering law
Philippine Daily Inquirer, December 2012

Britain is urging the Philippines to pass reforms that will strengthen the country’s anti-money laundering law, saying the proposed legislation would help plug corruption and funding for terrorists.

Steph Lysaght, First Secretary of the British Embassy in Manila, made the call as he cited how the government’s efforts to stop corruption have helped generate investor interest into the country.

“By ensuring that proceeds of corruption are discovered and recovered, the Philippines will be able to better deliver public services. Additionally, blocking access to funds for terrorist activities leads to greater peace and security not just in the Philippines but the Asia Pacific region,” Lysaght said.
The UK diplomat made the statement at a British-funded training course on the implementation of stronger anti-money laundering measures held at the Bangko Sentral ng Pilipinas Complex from November 26 to 29.

The training gathered Philippine officials from agencies involved in enforcing the Anti-Money Laundering Act, from detecting and investigating violations to prosecuting known violators.

The International Governance and Risk Institute or GovRisk, a UK non-governmental organization that conducts international training on combating financial crimes, administered the training that touched on “proliferation financing, forensic investigation and national risk assessment,” the UK Embassy said.

The training was held as the Philippines moved closer to passing amendments to the AMLA, a measure certified as urgent by President Aquino  and is up for deliberation in Congress.

“I know that everyone is waiting for the passage of the third and final amendment to the anti-money laundering act. We hope that it will be passed. The anti-corruption initiatives are a big part of why there is increased interest from companies to work in the Philippines,” Lysaght said in opening the training course.

Laundered money accounts for roughly 2.7 percent of the world’s gross domestic product, BSP Governor Amando Tetangko said in remarks at the event, according to the UK Embassy.

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