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AML Casino Guidelines Consultant

AMERICAN BAR ASSOCIATION, ROLI

TERMS OF REFERENCE

TITLE:

AML Casino Guidelines Consultant

PROJECT:

Transnational Anti-Money Laundering Assistance Program – Disrupting Money Laundering through Gambling (DMLG)

LOCATION:

Hanoi, Viet Nam

EXPECTED DURATION:

January 2022 - March 2023

ABA Rule of Law Initiative (ABA ROLI) is a non-profit pro­gram that implements legal reform programs in roughly 40 countries around the world.  ABA ROLI has nearly 400 professional staff work­ing internationally. ABA ROLI’s partners include judges, lawyers, bar associations, law schools, court administrators, legislatures, ministries of justice and a wide array of civil society organi­zations. 

PROJECT BACKGROUND

With funding of the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs (State/INL), ABA ROLI is implementing a 36-month (September 30, 2020 to September 29, 2023) Transnational Anti-Money Laundering Assistance Program - Disrupting Money Laundering through Gambling (‘DMLG’). The AML Gambling Program aims to generate multi-jurisdictional support for a common vision for enhancing the Anti-Money Laundering (AML) regime in the casino sector in the Greater Mekong Subregion including Thailand, Laos and Vietnam. The program has four sub-objectives including:

  1. Work with regulators and lawmakers to ensure jurisdictions have appropriate legal frameworks in place to regulate casinos and online gambling, with regard to measures to prevent, detect, and report money laundering,?according to international standards, and facilitate the crafting of legislation in select countries;
  2. Build capacity of?competent regulators?to?understand,?appropriately identify, and detect?money laundering;
  3. Help the competent authority to conduct outreach sessions with casinos, specifically increasing awareness of: a) who reports; b) expectations and c) how to appropriately file STRs;
  4. Work with company compliance officers and managers to ensure they are appropriately filing STRs with regulators, tracking money laundering threats, trends, and vulnerabilities, cooperating as appropriate with law enforcement officials,?and taking any other necessary compliance measures.? Gather feedback from regulators as to whether there is improved quality in compliance and develop follow-up actions accordingly.

Under sub-objective 3&4, as a part of the Casino and Online Gaming sector Guidelines, the AML Guidelines/Handbook for Casinos and Prize-winning games businesses (“AML Guidelines for reporting entities”) will be developed based on the Handbook which is drafted and finalized by the ABA ROLI International Expert. The AML Guidelines for reporting entities will assist reporting entities, including casinos, lotteries and prize-winning games businesses in implementing their AML duties in accordance with AML law and legislation.

To this end, ABA ROLI, in consultation with local partners, will engage a qualified consultant to develop AML Guidelines for reporting entities with objectives, expected outputs and other requirements as specified herewith.

OBJECTIVE OF THE ASSIGNMENT

The objective is to develop AML Guidelines for reporting entities in the casino and prize-winning games sector. The Guidelines will include basic information on AML and show how reporting entities can fulfill their AML duties and responsibilities. The AML Guidelines for reporting entities will set out step-by-step guidance for casinos and prize-winning games businesses on implementing their AML duties as reporting entities under AML Law and other legislations and will include a Suspicious Transaction Report template as an annex to it.

ABA ROLI will also conduct training on how to use the Guidelines and related annexures.

SCOPE OF WORK AND EXPECTED OUTPUTS

Subject to further discussion between the consultant and ABA ROLI - DMLG Program Director in Vietnam, the consultant will undertake the following tasks:

  • Task 1: Provide comments on the Draft of the Handbook, which the ABA ROLI International expert develops, through feedback and inputs from reporting entities
    • Get feedback from reporting entities on the draft of the Handbook (by consulting with reporting entities on roundtable discussion or by other means)
    • o   Provide comments on the Draft of the Handbook
    • o   If possible, participate in the Awareness raising workshop for reporting entities to introduce Handbook and get comments /feedback from reporting entities. 
  • Task 2: Draft the AML Guidelines for Reporting Entities and STR Template as Annexure
    • Develop outlines of the AML Guidelines for reporting entities and an STR template  
    • Draft and consult with key stakeholders and reporting entities during the development of the AML Guidelines for Reporting entities and the STR template.  
    • Incorporate feedback/inputs from ABA ROLI and relevant agencies/reporting entities into the Draft of the AML Guidelines for reporting entities and an STR template.
    • Finalize the AML Guidelines for Reporting entities and an STR template to achieve the objectives of the assignment.
  • Task 3: Participate in the workshop and deliver training to Reporting Entities on using the AML Guidelines for reporting entities and STR template
    • Participate in an one- day training workshop for reporting entities on using the Guidelines and STR template (tentatively in the second half of 2022)
    • Deliver training to reporting entities on using the AML Guidelines for Reporting entities and STR template.
    • Ensure the quality of the training.
  • Task 4: Report on the results of using the AML Guidelines for reporting entities and STR template
    • Get feedback from reporting entities on the application of the AML Guidelines for reporting entities and STR template.
    • Collect information on the number and quality of the STRs submitted by sector to FIU in 6 months following the training event.
    • Report on the result of using the AML Guidelines for reporting entities and STR template
  • Other tasks as required by ABA ROLI related to the AML Guidelines for Reporting entities and STR template to ensure the effectiveness of the activity.

KEY DELIVERABLES AND PAYMENT 

No.

 Deliverable

Deadline

1

Provision of comments on the Draft of the Handbook.

January/2022

2

Introduction of the Assessment Tool and the Handbook in the Awareness raising workshop for reporting entities and get feedbacks/comments

Feb/2022

3

Submission of a draft outline of the AML Guidelines for reporting entities and STR template

Mar/2022

4

Submission of the draft of the AML Guidelines for Reporting entities and STR template

Jun/2022

5

Collection of comments from the sector and submission of the final AML sector Guidelines and   STR template

Aug/2022

6

Delivery of training on using the AML Guidelines for reporting entities at the workshop for casino and prize-winning games operators

Sep/2022

7

Submission of the report on the results of using the AML Guidelines for Reporting entities and an STR Template

Mar/2023

Payment will be made based on the following milestones upon submission of the corresponding deliverables to the satisfaction of ABA ROLI.

Deliverable

Instalment

Deliverables 1, 2

20% of contract value

Deliverable 3,4

40% of contract value

Deliverable 5

30% of contract value

Deliverable 6

10% of contract value

PERFORMANCE PERIOD

The consultant will commence the above tasks from the signing date on the contract and end when all key deliverables are completed and confirmed by ABA ROLI DMLG Program Director, but no later than August 31, 2023.

REPORTING AND PROGRESS CONTROL

The consultant is accountable to ABA ROLI (and MOF/SBV, if those agencies participate in the process of choosing the consultant) on the timeliness and quality of deliverables. The consultant will report to ABA ROLI (and MOF/SBV) on the work progress on a regular basis. ABA ROLI will provide overall coordination among the different stakeholders, facilitating the consultant’s contact with Government officials to seek consultations with the relevant government partners (MOF, SBV, etc…).

Reporting and progress updates:

  • Upon contract signing, the consultant will work closely with ABA ROLI Program Director to discuss and agree on the task requirements and working methodology.
  • ABA ROLI (and MOF/SBV and the relevant stakeholders, if needed) will review and comment on the consultant’s required deliverables as specified in this TOR.
  • ABA ROLI shall disburse instalments to the consultants against the payment milestones set out above.

QUALIFICATIONS AND EXPERIENCE

The consultant should meet the following minimum requirements:

  • A post-graduate or equivalent qualification/degree in Law or economics/finance;
  • A minimum of 7 years of working experience on dealing with AML issues and/or financial sector issues, preferably on dealing with regulatory issues in casinos and prize-winning games sector;
  • Extensive knowledge of Vietnam AML regime, existing AML law and regulations as well as casinos and prize-winning games sector regulations;
  • Ideally, previous experience demonstrated ability of involving key stakeholders (government agencies and ministries) to provide relevant expertise and bring a wider perspective in consultation;
  • Strong background in research and writing;
  • Proven experience in delivering/facilitating stakeholder/working group consultations/ workshops and working with relevant government agencies.
  • Proficiency in written English is advantage.

HOW TO APPLY:

Please send a resume/CV and cover letter describing your relevant experience to Tran Ngoc Linh at email address: [email protected]

Organization: ABA ROLI
Location:
Application deadline: 2022-01-30
Send application to: [email protected]