Gaming & Leisure Association of Ireland

Lobbying Organisation Gaming & Leisure Association of Ireland

Date published 19 May, 2016

Relevant Matter Legislation

Public Policy Area Justice and Equality

Period 1 Jan, 2016 to 30 Apr, 2016

Specific Details Gambling Control Bill 2013 and the adoption of certain discretionary provisions contained in the 4th EU AML Directive

Intended results To advance the drafting and enactment of the Gambling Control Bill 2013 into legislation

Name of person primarily responsible for lobbying on this activity David Hickson

Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?) No

Did you manage or direct a grassroots campaign? No

Was this lobbying done on behalf of a client? No

Lobbying activity

The following activities occurred for this specific Subject Matter Area.

Letter (1)

Letter to the Minister for Justice, Francis Fitzgerald T.D providing observations based upon the experience in the UK to support the need to update gambling legislation in Ireland.

Submission (1)

Further to the Department of Finance's invitation to engage in public consultation, the GLAI made a Submission to the Department on the 4th EU Anti-Money Laundering Directive and Funds Transfer Regulation. Our submission focused on Article 2(2) which provides that following an appropriate risk assessment, member states may decide to exempt certain gambling services providers (with the exception of casinos) from the requirements of 4AMLD on the basis of proven low risk posed by such services. Our Submission found that based on evidence obtained in the Irish and other regulated jurisdictions there existed a significant AML risk across all forms of gambling service providers. Accordingly we concluded that no exemptions to comply with the 4th AML Directive should be granted. We also found that Ireland was in breach of FATF Recommendation 28 which stipulates that all casinos should be licenced.

Letter (1)

Letter to the Minister for Finance, Michael Noonan T.D setting out the anti-money laundering issues that surround the gambling industry. We attached a copy of our submission to the Dept. of Finance on the 4th EU AML Directive for his attention and provided an overview of how the AML risks associated with all forms of gambling service providers could be mitigated by progressing the Gambling Control Bill 2013.

Designated public officials lobbied

The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them. As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.

Frances Fitzgerald Minister (Department of Justice and Equality)

Michael Noonan Minister (Department of Finance)