of ‘freemium’ model gaming and of skill or are provided at a physical similar models has the issue of what location or at distance. Gambling constitutes ‘gaming’, and the various businesses within scope are subject subtleties involved, become more to requirements regarding customer of an issue. The characteristics of a due diligence, suspicious activity game will need to be considered on a reporting, anti-money laundering case-by-case basis. (AML) policies and procedures and registration with a relevant AML compliance for operators supervisory authority. However, the The EU’s Fourth Money Laundering customer due diligence measures Directive (MLD4) and Fifth Money for gambling services only apply to Laundering Directive (MLD5) have transactions worth EUR2,000 or more been transposed into UK law largely (including both the value of the stake through the Money Laundering, and winnings). MLD5 did not change Terrorist Financing and Transfer of the position regarding the ability Funds (Information on the Payer) to exempt low-risk gambling Regulations 2017 (MLRs) and The businesses from scope. Money Laundering and Terrorist Financing (Amendment) Regulations Gambling Act 2005 2019, which came into effect on 10 Businesses holding gambling licences January 2020. in the UK must also bear in mind their obligations under the GA, and the MLD4 and MLD5 licensing objectives which include, MLD4 extended the scope of money among other things, preventing laundering regulation to the provision gambling from being a source of, or of ‘gambling services’. ‘Gambling associated with, crime or disorder or services’ means services that involve being used to support crime. wagering a stake with monetary value in games of chance, whether or not they also involve an element 148