Anti-Money Laundering Risk Assessment Policy
1. Principle risk areas of Council and Gatherwell lottery systems being abused for AML practices fall into 2 key areas:
1.1. Criminal laundering of money through the purchase of tickets on one of Gatherwell's local authority lottery sites and subsequent winnings from draws taken as 'cleansed' money.
1.2. False registration and representation of good causes on one of Gatherwell's local authority lottery sites against which tickets are purchased against to launder illegally acquired funds and to be extracted through the false pretence of funds raised for a good cause.
2. Barriers and restrictions that are currently in place to deter the above practices are as follows:
2.1. Ticket purchases are limited per participating player therefore making it impossible to buy a large amount of tickets. Therefore activity would require the registration of an extremely large number of individual user accounts for money laundering of significant value.
2.2. The maximum return possible from laundering through the purchase of tickets is extremely low in comparison to other gambling activities. Statistically, a maximum of 26% of proceeds are allocated to prizes across all of Gatherwell's lottery campaigns.
2.3. In order to ensure the legitimacy of the good causes registered on the Council & Gatherwell sites, there is a good cause validation process in place for all sites. For the proposed SHWD Council lottery, only good causes and charities which operate with South Hams and West Devon and meet certain criteria are accepted. A cause application and approval workflow process is in place. The council has a duty to verify the identity of every good cause prior to approving their inclusion and set up on their lottery website. This workflow is comprehensively tracked and logged on system records.
3. The outcome of the high level assessment of risk is as follows:
3.1. Council and Gatherwell lottery systems present a low risk of money laundering practices for the following reasons:
3.1.1. Transactions are limited to only small sums of money and would therefore require a lot of effort in the setting up of a large number of accounts to make the exploitation of Gatherwell lotteries a worthwhile laundering activity.
3.1.2. Setting up a good cause requires certification/validation from authorised government bodies which in itself is a deterrent.
3.1.3. The overall combination of risk, reward and effort would mean that the Council and Gatherwell is at low risk especially in comparison to alternative gambling activities.