AML IN GAMING: A MANUAL AGAINST CRIMINAL INFILTRATION IN THE INDUSTRY

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Written by Antonio Arrotino, AML Manager and MLRO of SKS365, and Prof. Ranieri Razzante, President of the. Italian Anti-Money Laundering Officers Association, the book portrays the current legal system and the measures to prevent and contrast organized crime’s intrusions in both offline and online gaming market.

IL GAMING – Prevenzione e contrasto alle infiltrazioni mafiose (GAMING - Prevention and fight against mafia infiltrations) is the title of the guide written by Antonio Arrotino, lawyer, AML Manager and MLRO of SKS365, together with Professor Ranieri Razzante, President of the Italian Anti-Money Laundering Association, professor of Anti-Money Laundering Legislation at the University of Bologna and vice-president of SKS365 supervisory body. With a further contribution from Luca Grisci, SKS365 Director of Retail.

It is a guide for operators and all professionals as part of the Italian gaming industry, a volume that includes the subjects involved, the current legislation, the types of risk and the measures to be taken to prevent potential interferences by crime within such a delicate and changing system and, therefore, particularly exposed to illicit interests.

"The purpose of money laundering deriving from criminal activity, as is well known, is to reintroduce into the legal economy those resources which have been drained from it through criminal activities, and which return to it in different ways, to allow to reinvest it in lawful activities – is written in the Preface signed by Roberto Fanelli, head of the Central Legal and Litigation Department of ADM, Italian gaming authority – The volume of Razzante, a well-known expert on this subject, and Arrotino, expert and operator in the sector, systematically deals with these issues, providing a complete picture and combining the necessary legal framework profiles with concrete operations."

The objective that Arrotino and Razzante set themselves in writing the guide arises from two considerations: the size of the damage that the crime of money laundering entails for the Italian economic system – almost 120 billion a year – and the evidence that criminal infiltrations in the gaming chain occur to the detriment of the concessionaires themselves and almost never with their complicity. Nonetheless, there is the false myth that associates the game with the crime on several levels (political, journalistic and social). This has resulted to picture the gaming sector as an enemy of of Authorities and Institutions rather than as an ally.

“The gaming sector, like other sectors that generate high money movements, catches the interest of criminality. In Italy the illegal game is worth a fifth of the legal one – commented Antonio Arrotino – However , an increasingly fundamental contribution in the fight against crime has come from the operators of the sector in the recent years, primarily from the concessionaires themselves, who are become authentic sentinels of illegal and potentially illegal behaviours, as evidenced by the significant increase in reports of suspicious transactions to the police. This is a twofold commitment: on one hand the State Authority, on the other the operators and dealers, in a relationship based on trust, involvement and above all awareness of the tools to defend the clean system."

"We wish that this book will help to dismantle some prejudices, in the Authorities and Institutions, according to which the gaming sector is dominated by crime where, on the contrary, crime would find easy way in a market that is not sufficiently controlled – added Prof Ranieri Razzante – For a long time I’ve been supporting the need to issue a Single Text on the Game to collect all regulatory sources, currently dispersed everywhere, and to allows operators and the police themself to follow their technical and legal evolution."

This book reconstructs the entire ecosystem around gaming in Italy, institutional actors, entrepreneurial subjects, typology of existing products and services, analazying the business units to identify the potential vulnerabilities of the industry, i.e. the areas in shadow where the concrete risk of criminal infiltration lurks. It concludes with a detailed regulatory overview of the obligations of dealers and operators, together with reporting methods and authorities in charge of surveillance and intervention.

The volume is published by Pacini Giuridica, a publisher specialized in the publication of manuals in the artistic-cultural field and in-depth scientific, academic and regulatory study.

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