The prevention of money laundering and the financing of terrorism
Supporting records (gaming machines)
7.21 Cash-in with cash-out gaming machines do not produce any supporting records that can be attributed to a customer. They do generate overall cash-in and cash-out data that must be retained by the casino. However, ‘ticket in, ticket out’ (TITO) and ‘smart card’ technology may mean that machines produce supporting records that can be attributed to a customer who falls within the record keeping requirements, in which case such records must be retained in accordance with the Regulations.
7.22 The essentials of any system of monitoring are that:
- it flags up transactions and/or activities for further examination
- these reports are reviewed promptly by the nominated officer
- appropriate action is taken on the findings of any further examination.
7.23 Monitoring can be either:
- in real time, in that transactions and/or activities can be reviewed as they take place or are about to take place
- after the event, through the nominated officer’s review of the transactions and/or activities that a customer has undertaken.In either case, unusual transactions or activities should be flagged for further examination.
7.24 In designing monitoring arrangements, it is important that appropriate account be taken of the frequency, volume and size of transactions with customers, in the context of the assessed customer risk.
7.25 Monitoring is not a mechanical process and does not necessarily require sophisticated electronic systems. The scope and complexity of the process will be influenced by the casino operator’s business activities, and whether the operator is large or small. The key elements of any system are having up-to-date customer information, on the basis of which it will be possible to spot the unusual, and asking pertinent questions to elicit the reasons for unusual transactions or activities in order to judge whether they may represent something suspicious.
Next chapter: Retention period