Anti-Money Laundering

1.The Role of the HGC in Combating Money Laundering and Terrorist Financing

The Hellenic Gaming Commission (HGC) applies a risk-based supervisory approach to prevent and combat money laundering and terrorist financing. Under this framework, Obligated Persons, including entities that organize or conduct games of chance within the Greek territory, whether through land-based networks or online channels, as well as casino enterprises, are required to identify, assess, and effectively manage the money laundering and terrorist financing risks arising from their activities. The HGC tailors the scope and intensity of its supervisory actions according to the level of risk identified.

In carrying out its statutory responsibilities, the HGC:

1. Issues regulatory decisions, guidelines, instructions, and circulars to clarify and specify the obligations of Obligated Persons.
2. Monitors and assesses compliance with the applicable anti-money laundering and counter-terrorist financing (AML/CFT) legal and regulatory framework.
3. Collects and analyzes data and information relating to the implementation and effectiveness of AML/CFT measures.
4. Conducts both on-site and remote inspections to evaluate compliance and identify potential deficiencies.
5. Assesses money laundering and terrorist financing risks within the gambling sector and develops appropriate supervisory responses.
6. Imposes administrative measures, corrective actions, and sanctions in cases of non-compliance with regulatory requirements.
7. Cooperates closely with the Hellenic Anti-Money Laundering Authority, law enforcement agencies, other competent national authorities, and relevant European and international organizations to strengthen the effectiveness of AML/CFT efforts.

This risk-based and collaborative approach enables the HGC to safeguard the integrity of the gambling sector and contribute to the prevention and detection of money laundering and terrorist financing activities.

2. Legislative and Regulatory Framework

The framework for the prevention and combating of money laundering and terrorist financing in the gambling sector is primarily based on the following legislative, regulatory, and international instruments:

1. Law 4557/2018 – Prevention and suppression of money laundering and terrorist financing, as amended and in force.
2. HGC Decision 554/5/15.04.2021 – Regulation on the implementation of anti-money laundering and counter-terrorist financing (AML/CFT) measures by Obligated Persons operating in the gambling services market.
3. National Risk Assessment (NRA) Report – Assessment of money laundering and terrorist financing risks at the national level, providing guidance for the application of a risk-based approach.
4. European Commission Supranational Risk Assessment (SNRA) – Assessment of money laundering and terrorist financing risks affecting the European Union.
5. Financial Action Task Force (FATF) Publications and Statements – Including information on jurisdictions subject to enhanced monitoring or identified as high-risk.
6. United Nations and European Union Sanctions Regimes – Restrictive measures adopted by the United Nations Security Council and the European Union to combat terrorism, proliferation financing, and other threats to international security.
7. European Union Financial Sanctions Lists – Consolidated lists of designated persons, entities, and groups subject to EU financial restrictive measures.
8. United Nations Security Council Consolidated List – The list of individuals, groups, undertakings, and entities subject to sanctions imposed by the United Nations Security Council.

3. Obligations of Obligated Persons

Obligated Persons operating within the gambling services market are required to implement effective measures for the prevention and combating of money laundering and terrorist financing, in accordance with Law 4557/2018 and HGC Decision 554/5/15.04.2021.

In particular, they must:

1. Conduct and regularly update risk assessments to identify, evaluate, and mitigate money laundering and terrorist financing risks associated with their activities.
2. Establish, implement, and maintain appropriate AML/CFT policies, procedures, and controls.
3. Apply customer due diligence (CDD) measures, including customer identification and verification, in accordance with the level of risk.
4. Monitor customers’ transactions and gaming activity on an ongoing basis to detect unusual or suspicious patterns of behavior.
5. Appoint a Compliance Officer with responsibility for overseeing AML/CFT compliance and reporting obligations.
6. Maintain effective internal control, governance, and risk management systems proportionate to the nature and scale of their operations.
7. Ensure that employees receive regular and appropriate AML/CFT training to enable them to identify and manage relevant risks.
8. Maintain adequate records, documentation, and data in accordance with statutory retention requirements.
9. Promptly report suspicious transactions and activities to the competent authorities, in accordance with applicable legal requirements.
10. Cooperate fully with the Hellenic Gaming Commission (HGC), the Anti-Money Laundering Authority, and other competent national and international authorities in matters relating to AML/CFT compliance.

4. FATF High-Risk Jurisdictions and Sanctions

Obligated Persons are required to take into account the statements and publications issued by the Financial Action Task Force (FATF) regarding high-risk jurisdictions and jurisdictions under increased monitoring, as well as the financial sanctions regimes imposed by the United Nations and the European Union.

Where transactions or business relationships are associated with high-risk jurisdictions or involve individuals, entities, or organizations included on applicable sanctions lists, Obligated Persons must apply enhanced due diligence measures and ensure compliance with all applicable restrictive measures and sanctions requirements.

Publications FATF

The following table presents, by date of publication, the FATF public statements regarding high-risk jurisdictions subject to a call for action and jurisdictions under increased monitoring.

Reports – Surveys

5. Risk Assessment (NRA / SNRA)

Obligated Persons must take into account the findings and recommendations of both the National Risk Assessment (NRA) and the European Commission’s Supranational Risk Assessment (SNRA) when conducting their own risk assessments and when designing and implementing policies, procedures, and controls for the prevention of money laundering and terrorist financing.

The AML/CFT framework is based on the risk-based approach, under which Obligated Persons are required to identify, assess, understand, and mitigate the risks to which they are exposed. Consequently, the nature and extent of the preventive measures applied should be proportionate to the level and type of risk identified.

6. European AML/CFT Framework

European Anti-Money Laundering Authority (AMLA)

The European Union has established the European Anti-Money Laundering Authority (AMLA) to strengthen the effectiveness and consistency of the Union’s anti-money laundering and counter-terrorist financing (AML/CFT) framework.

AMLA is expected to play a central role in enhancing supervisory convergence, fostering cooperation among competent authorities, and promoting the uniform application of AML/CFT rules across Member States. In particular, AMLA will contribute to the development of common supervisory practices, facilitate coordination between national authorities, and support the prevention and detection of money laundering and terrorist financing at the European level.

For more information: AMLA

EU AML Legislative Package

The European Union has adopted a new legislative framework for the prevention of money laundering and terrorist financing, commonly referred to as the EU AML Package. The package aims to establish a single and consistent AML/CFT rulebook across the European Union, strengthen supervisory arrangements, and enhance cooperation and information sharing between competent authorities.

The new framework includes regulations and directives relating to AML/CFT requirements, the establishment and operation of AMLA, transparency of beneficial ownership, customer due diligence requirements, and the traceability of funds transfers.