AML: основы для гейминга

Gambling — high-risk sector per FATF. AML compliance — обязательная функция лицензированного operator.

Framework

Customer Due Diligence (CDD): identify, verify at onboarding. Enhanced Due Diligence (EDD): для high-risk. Ongoing monitoring: transactions vs profile. Suspicious Activity Reporting (SAR): mandatory. Record keeping: 5+ years. Staff training.

Roles

MLRO (Money Laundering Reporting Officer): senior management, accountable. Compliance officer: day-to-day operations. Board oversight. Independent review: annual. Segregation of duties. Escalation procedures.

Risk assessment

Business-wide: overall risk profile. Customer risk: PEPs, high-risk countries. Product risk: crypto higher, direct debit lower. Geographic risk: sanctions countries, high-risk juris. Delivery risk: online vs face-to-face. Updated annually.

Technology

Transaction monitoring: automated + rules. Sanctions screening: real-time. PEP databases. Adverse media monitoring. Blockchain analytics для crypto. Alert management systems. Investigator workflows. Case management. Regulatory reporting automation.