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Conferences in Europe

Exclusive interview with Alex Henderson(Head of AML at The Ritz Hotel Casino), speaker at Prague Gaming Summit

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Dear readers and subscribers,

Thank you for following my interview series and for sharing these information with your colleagues and partners. If you would like to be featured in an upcoming interview, please send me an e-mail to reka.szalo@europeangaming.eu and I will happily get back to you!

Moving forward, I would like to introduce my latest interviewee, Alex Henderson, who is the current Head of AML at The Ritz Hotel Casino and also a speaker at our upcoming live event/conference in Prague.

Thank you for your time and I hope you will gain vital information needed for your business in regards to AML and AMLD 4.

I would like to thank you for spending time to answer our questions. First I would kindly ask you to shortly introduce yourself.

Alex: I am the current head of AML at one of the UK’s top Mayfair casinos as well as a trainer for the global leader in AML/social responsibility training for gambling operators (AML Gaming Solutions). I have worked for the past 7 years for the National Crime Agency as a financial investigator and within the AML expert witness team as well as within covert operations where I portrayed many roles within counter terrorism, drugs. The most relevant to my current career is that I portrayed the role of an international money launderer.

Would you please speak about the effects of AMLD 4 on the gambling industry in geneneral and in the UK in particular?

Alex: My opinion is that in general the 4th MLD has had little impact for some operators but major impact for many others (if they have made the appropriate changes). The main impact came from the requirement to “know your customers” better which for many land based operators it is not a huge change, as many of them already go a long way to know about their clientele. For many online operators this was a tough change as my opinion is that many operators do the bare minimum when it comes to due diligence. Overall, I think that many operators do not even have measures in place to comply with law from 2002 (proceeds of crime act 2002), so I would not expect those operators to be doing anything to comply with law that has been in place less than 10 months. The reason I say this is because many of the MLRO’s (money laundering reporting officer) or AML managers I speak with know very little about money laundering/financial crime or their roles and responsibilities and the relevant laws and regulations.

You advise large number of organisations with regards to their AML compliance programmes. According to your experience what are the most frequent problems, issues regarding this topic?

Alex: Lack of knowledge is number 1. I am not just referring to the lower level employees but with MLRO’s and AML managers, the level of knowledge sometimes scares me. I have met with MLRO’s who did not know how to input a SAR (Suspicious activity report), some did not know basic money laundering techniques and how to identify them… then these MLRO’s are entrusted to protect the business and oversee staff training, so it is effectively the blind leading the blind. I speak with some businesses who tell me that they are low risk for money laundering or that criminals do not use their business…. When I tell them that I myself have actually laundered money through their business or have spent criminal proceeds through their business they have a sudden change in attitude, which for me is a good thing. Many gambling employees have not been given the basic knowledge for preventing financial crime which is the fault of the operator. I enjoy giving staff this knowledge and empowering them to detect criminality and prevent those criminals using their businesses.

What social responsibilities does preventing money laundering include?

Alex: In many cases, social responsibility and AML go hand in hand. If an operator has good AML processes in place they will often detect problem gambling concerns and vice versa. We have seen in the recent enforcement action that when an operator is punished for their lapses in social responsibility they are also punished for their lapses in AML, this is because operators generally do not do enough to protect their customers. If an operator has done enough to determine a customer’s Source of Wealth (SOW) they should know when that customer is spending more than they can afford. Therefore if that customer is spending outside of their known income, an operator should be doing extra checks to determine if the customer is spending more, because they either have a gambling problem or they are spending more because they also have some illegitimate funds that have not previously been uncovered.

There are new regulations in this domain. Will you please speak about these and their effects?

Alex: Operators are expected to do more, and rightly so. The expectation from the regulator is that both remote and non-remote operators need to step up and start protecting customers. But this is difficult and causes a huge conflict of interest amongst operators; on one hand they are trying to run a profitable business, keep customers gambling and spending money, on the other hand they are expected to stop customer if they gamble too long or spend too much money. The punishment for not protecting customers is too soft in my opinion. The gambling commission should be taking licences and giving hefty fines, at the moment operators get away with doing very little to protect customers. Operators would do a lot more if they genuinely felt their licence was on the line or that they would be fined excessively. If we take the banking industry as an example, it took HSBC getting fined £250m for all the banks to start carrying out adequate AML due diligence, before the HSB fine banks always done the minimum because they knew any fine they received would be worth paying. I think the gambling commission is definitely moving in the right direction but they need to send out a clear message, the way to do that is to start making examples of operators.

What about the UK? Where is it heading with the new regulations?

Alex: I think the gambling commission is going to get tougher and tougher on operators until the operators eventually start looking after their customers. UK operators need to do more, especially online. There is a poor knowledge of AML and even worse knowledge on problem gambling when it comes to online operators. Staff needs to be given proper training so they can protect the businesses and their legitimate customers. I think more regulation will keep coming and will keep getting harder until operators take it upon themselves to start protecting customers.

What do you think what is gaming considered by the people of the UK today; are they satisfied with the new changes?

Alex: Public trust in gambling has drastically decreased; this is because of all the negative media on problem gambling and money laundering. I think the public are happy that the industry is under such scrutiny because financial crime and problem gambling effects so many people. Operators have the power to regain trust from the public and I do think all the changes the commission and the government are trying to make will help to regain public trust once again.

What would you change in the present state of the British gambling market?

Alex: I would make it a requirement for operators and all staff to undertake adequate and relevant training on both AML and problem gambling. Many operators put staff through poor internal courses or e-learning programs which is not good enough. AML Gaming Solutions (AMLGS) are made up of AML experts who have worked for law enforcement, government and regulators. They deliver face to face training to all staff from the ground all the way up to the CEO which is highly important. Every operator should be undertaking training from experts such as AMLGS. It is vital for staff to hear from professionals and to understand what a vital role their play in preventing financial crime and protecting customers

What is your personal opinion about gambling industry in general in Europe?

Alex: I think that the industry is moving in the right direction, the constant updates in law and regulation are a good thing and operators need to embrace the changes. I do believe that from compliance perspective more needs to be done by operators, but we are getting there slowly. The industry is going to continue to grow; it is this growth that has brought the attention of various governments and law enforcements. Five years ago the industry was not on anyone’s radar but now every government in the world has taken an interest. This scrutiny has brought a well-deserved pressure to operators who have for many years failed to prevent financial crime; I think the message is clear: step up and do more or be on the receiving end of some very harsh penalties.

To hear more about the subject and meet Alex in person, make sure you register and attend Prague Gaming Summit 2018, held on the 29th of March at Andel’s by Vienna House Prague.

Interviewee profile:

Alex specialises in preventing money laundering in its varying forms and has a very unique insight that is hard to find.

Alex Henderson is the current Head of AML at The Ritz Hotel Casino, one of the worlds most prestigious casinos. Alex has worked for the National Crime Agency (NCA) as part of the AML expert witness team and has been involved in multiple high end money laundering investigations. As well as having worked for several years as part of the NCA’s AML expert witness team, Alex spent much of his NCA career working as part of the covert operations unit (Undercover operations) portraying many different roles, including the role of a high end money launderer. This unique insight into the mind of a criminal allows financial institutions to see the vulnerabilities and risks from a new angle. Alex advises a large number of organisations with regards to their AML compliance programmes and has lectured extensively in the UK and across Europe.

EXPERIENCE
• Successfully delivered AML training workshops to a large banking group with over 4000 employees
• Advises money service bureaus, banks and regulated businesses on their AML risks
• Operated in a covert capacity in various operations across the UK, portraying the role of a money launderer amongst many others
• Involved in many high profile investigations involving trade based money laundering and sector focused laundering
• Advised leading organisations on the financial crime risks and vulnerabilities impacting their business
• Delivered training to multiple financial institutions and developed staff knowledge of AML across over 100 organisations to date
• Leading the AML team at one of London’s top casinos, handling high risk members and overseeing the due diligence of the business customer database
• Advised a major bank in regards to their AML fine and enforcement action on best practice moving forward
• Involved in various counter terrorism and AML Law Enforcement operations across the UK

Reka is an Experienced English second language teacher with a demonstrated history of working in the higher education industry. Skilled in Microsoft Excel, Teaching English as a Foreign Language, Translation, Foreign Languages, and Lecturing. Strong education professional with a Bachelor’s Degree majored in English Language and Literature/Letters. Reka is in charge of conducting the exclusive interviews on European Gaming and our printed magazine

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Conferences in Europe

Gambling in Czech Republic, Slovakia, Slovenia and Austria, moderated by Dr. Joerg Hofmann at Prague Gaming Summit 2018

Zoltan Tundik

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Prague – 21 February 2018 – The most important boutique style gaming conference in Prague is going to welcome leading experts of the online gambling industry on the 29th of March at Andel’s by Vienna House Prague. The second edition of Prague Gaming Summit is gathering new and old faces of the industry in order to highlight the trending topics for the attending delegates.

The key to a successful panel is in the careful selection of the panel moderator. The panel moderator brings the session to life: often selecting and prepping the panelists, determining the format to ensure a lively and informative conversation and having excellent facilitator skills to keep the conversation focused and moving along.

We have always searched to find the best possible mediators for the panel discussions and Prague Gaming Summit will continue to bring these quality dialogues.

The latest announced moderator is a familiar face at gaming events and is known for his experience in the industry. Dr. Joerg Hofmann (Melchers Law Germany) is the Immediate Past President of the International Masters of Gaming Law (IMGL), the pre-eminent global gambling law networking and educational organisation. He has been consistently ranked as a “Leading Individual” in Gaming & Gambling by Chambers Global since 2011 and is the only German Lawyer listed among “Germany’s Best Lawyers” in the category “Gaming Law” by Handelsblatt and BestLawyers since 2014. Joerg is based in Heidelberg/Germany. He frequently publishes articles in international expert’s magazines and periodicals and speaks regularly on international gaming law conferences around the world.

Dr. Joerg Hofmann will moderate the “Focus on Czech Republic” and the “Focus on Slovakia, Slovenia, Switzerland and Austria” panel discussions, which promise to offer some inside information around the markets.

More speaker profiles will be releases soon, but you may want to check the already confirmed line-up of speakers and register in time. The event is limited to 125 seats.

Visit the official website of the event for more details: https://praguegamingsummit.com/

To hear more about the subjects and meet Joerg  in person, make sure you register and attend Prague Gaming Summit 2018, held on the 29th of March at Andel’s by Vienna House Prague.

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Conferences in Europe

Exclusive Interview with Piotr Dynowski (Partner and Head of IP, Media, Tech & Comms practice at Bird & Bird’s Warsaw Office)

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The Polish gambling industry has been the subject of many major changes, however not all of them are clear for the operators and shareholders.

So, I took advantage of the opportunity to catch up with Piotr Dynowski (Partner and Head of IP, Media, Tech & Comms practice at Bird & Bird’s Warsaw Office), who is going to be among the speakers at Prague Gaming Summit 2018 (more details here...), to gain an inside perspective on the Polish gambling market.

I would also like to thank you for following my interview series and for sharing these information with your colleagues and partners. If you would like to be featured in an upcoming interview, please send me an e-mail to reka.szalo@europeangaming.eu and I will happily get back to you!

I would like to thank you for spending time to answer our questions. First I would kindly ask you to shortly introduce yourself.

Piotr: My name is Piotr Dynowski and I’m a partner and head of IP, Media, Tech & Comms practice at Bird & Bird’s Warsaw office. For over 10 years now, as part of my practice, I have advised clients on all aspects of gaming law, in particular online gambling and betting, social gaming and e-sports. I advise on licensing regimes, regulatory issues, as well as advertising and provision of B2B services to gambling operators.

What is your personal opinion about the European gambling industry and could you make a comparison with the market that you know better and the European situation in terms of gaming and gambling?

Piotr: Unfortunately, Poland is still one of the most restrictive markets in Europe with respect to gambling and doing business by gambling operators in Poland is still pretty difficult, but apparently the changes to the Polish gambling regulations introduced last year were quite beneficial to the licensed betting operators and helped them almost double their turnover in comparison to the previous years. In general running gambling business, even in the EU, is very difficult as legal regulations differ significantly from country to country, some are very restrictive, others pretty liberal, and it is one of probably very few industry sectors left in the EU that are still completely unharmonised and where it seems the fundamental freedoms on which the EU is based do not really apply. Gambling industry has also to struggle all the time with negative perception by many governments and sometimes also negative image in the society. Generally gambling is still often perceived as something a little doggy and causing a lot of harm to the society despite all the efforts of the industry towards fraud protection, fighting gambling addiction and other important initiatives to prove that it is not a different industry than  any other entertainment industries.

In several Eastern European countries there are significant regulatory changes concerning online gambling. What advise would you give for the operators; which are the most attractive markets?

Piotr: Yes, we have seen recently some major changes to the gambling regulations in several Eastern European countries, but unfortunately most of them did not have too much impact on the situation of the private operators. Either they aimed at expanding and strengthening of the state monopoly like in Poland or Hungary or in theory created new opportunities for private operators to apply for new licences, but in practice turned out to be impossible to complete as in the Czech Republic. It seems that only Romania with its relatively liberal regulation in the region sees a major growth of its gambling market. The next big thing in Europe will most probably be Sweden which after years of strict monopoly will open soon to private operators. Taking into account that already a big number of companies in gambling industry are in fact of Nordic origin, the opening of the Swedish market will create enormous opportunities.

I would like to ask you to speak about the recent updates of the Polish gambling market. What can be expected in 2018 in terms of regulations, changes in this particular industry in Poland?

Piotr: Unfortunately, I’m afraid, there no major changes with respect to gambling regulations in Poland that we can expect in 2018. In my view any major future changes will depend on how successful the new online casino operations of the state monopoly will be, but there are delays with the launch of it, so it will take still some time to see how they are doing. If it is successful, the Polish government will have no incentive to liberalise the regulations and to let the private operators compete with the monopoly. But if it is a failure, they may reconsider whether it is not better to allow private operators to operate more freely and generate revenue for the state from the taxes. The only area where there may potentially be some changes in the foreseeable future is lowering slightly the taxes on gambling in Poland as they are currently very steep and one of the reasons many operators do not even try to apply for a licence here. Such change would certainly be welcome by the industry and could generate some more action on the market.

To hear more about the subject and meet Piotr in person, make sure you register and attend Prague Gaming Summit 2018, held on the 29th of March at Andel’s by Vienna House Prague.

Interviewee profile:

Piotr is one of the leading Intellectual Property, patent and IP litigation lawyers in Poland.

Piotr advises on all aspects of gaming law, in particular online gambling and social gaming. His expertise covers licensing regimes, regulatory issues as well as advertising and provision of services such as electronic payments in relation to gambling products.

In 2011, as the Polish expert he participated in the research conducted by Cambridge Health Alliance together with Harvard Medical School and Harvard Law School, investigating associations between European gambling regulations and the actual gambling behavior of players.

In 2011, he represented the two largest European online gambling industry organisations in complaint proceedings against Poland to the European Commission for violation of the EU law by Polish gambling regulations, which resulted in the European Commission launching proceedings concerning violation of the EU law by Poland at the end of 2013 which terminated only in January 2016 after a number changes to the Polish gambling regulations were introduced.

He is a legal expert of the Polish Chamber of Commerce

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Conferences in Europe

Exclusive interview with Tom Edmonds (Harris Hagan), speaker at Prague Gaming Summit 2018

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Reading Time: 4 minutes

It was my pleasure and honor to conduct the below interview with such a experience professional of the gambling industry.

I would also like to thank you for following my interview series and for sharing these information with your colleagues and partners. If you would like to be featured in an upcoming interview, please send me an e-mail to reka.szalo@europeangaming.eu and I will happily get back to you!

My current interviewee is Tom Edmonds (Harris Hagan), who is going to be among the speakers at Prague Gaming Summit 2018 (more details here...)

We are very grateful for your generosity to answer our questions. First I would like to ask you to shortly introduce yourself and tell us when and why you started working in this industry.

Tom: My first taste of working in the gambling industry was advising on the sale of a major gambling company, when I worked at Travers Smith (a UK firm specialising in corporate transactions).  This gave me an appetite to work in the industry and I moved in-house to Betgenius, a B2B sports betting provider.  I then continued my journey into the world of gambling when I joined the specialist gambling law firm Harris Hagan in 2014.

Before joining Harris Hagan in March 2014, you worked at Betgenius as an in-house solicitor. Which are those professional experiences or which is the knowledge you accumulated there and proved to be useful in your present job?

Tom: It was valuable to develop a detailed understanding of the sports betting sector, as well as a general overview of the rest of the industry.  This has enabled me to better assist clients by anticipating issues which a client has not necessarily considered but which I’m aware will come into play.

You advise clients on regulatory requirements from a gambling law perspective, product classification and on making operating license applications in the UK. Which are the most common problems your clients ask your help in and what are your most important suggestions?

Tom: We regularly assist clients with applications for a Gambling Commission licence.  At the outset this involves dealing with the fundamental question of which company/ companies need to be licensed and which licences they need to hold – a question which you might imagine to be simple, but which can be complicated and which is vital to get right.

We then work with clients to ensure they remain compliant with the requirements of holding a Gambling Commission licence and, if they should breach such requirements, assisting them in finding the best resolution.

In several Eastern European countries there are significant regulatory changes concerning online gambling. What is your opinion about the European market in general? What advise would you give for the operators; which are the most attractive markets?

Tom: In general, Europe is moving towards ‘point of consumption’ licensing regimes, as in Great Britain, where operators need a licence in each country from which they take play.  As a result, operators must be prepared to spend increasing amounts of time and money on compliance as they have to deal with the requirements of more licensing regimes.  Conversely, and with regards to the most attractive markets, there are still unregulated markets which may prove more profitable but which also carry a higher risk profile.

You are particularly interested in areas of this industry where sports and gambling meet. How would you characterize this area of the gambling industry and which are the new trends, important changes that you would like to speak about?

Tom: There has been a significant tightening of the rules regarding advertising of gambling, including those adverts shown around televised sporting events.  At the time of writing (mid-February 2018), the advertising regulator in Great Britain has just issued wide ranging new guidance that is intended to have a substantial impact on the content (and tone) of such adverts.  Adverts will have to change but we wait to see how significantly operators will change their adverts and what action is taken against non-compliant operators.

To hear more about the subject and meet Tom in person, make sure you register and attend Prague Gaming Summit 2018, held on the 29th of March at Andel’s by Vienna House Prague.

Interviewee profile:

Tom works in the Gambling Group and specialises in regulatory, commercial and corporate matters.

Before joining Harris Hagan, Tom worked as an in-house solicitor at Betgenius, a technology company which provides sportsbook solutions to bookmakers. At Betgenius, Tom gained first-hand experience of the online industry and advised on a broad range of commercial contracts and regulatory matters. Prior to working at Betgenius, Tom trained and worked for four years at Travers Smith where he specialised in M&A, including advising on the sale of a large gaming company.

Tom joined Harris Hagan in March 2014 and deals with all aspects of gambling law including advising major land based casino operators, online B2B and B2C operators and start up companies. Tom regularly advises clients on regulatory requirements from a gambling law perspective, product classification and on making operating licence applications in the UK. Tom has a particular interest in areas where there is a cross-over between sport and gambling including sports betting, advertising gambling at sports events and spot-the ball competitions

In his spare time, Tom enjoys playing or watching sport, planning adventures overseas and having the occasional flutter.

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