Preventing money laundering and the financing of terrorism
Evaluation and dtermination by the nominated officer
8.17 The casino operator’s nominated officer must consider each report and determine whether it gives rise to grounds for knowledge or suspicion. The operator must permit the nominated officer to have access to any information, including CDD information, in the operator’s possession that could be relevant. The nominated officer may also require further information to be obtained, from the customer if necessary. Any approach to the customer should be made sensitively and probably by someone already known to the customer, to minimise the risk of alerting the customer or an intermediary that a disclosure to the NCA is being considered.
8.18 If the nominated officer decides not to make a report to the NCA, the reasons for not doing so should be clearly documented or electronically recorded, and retained. These records should be kept separately by the nominated officer in order that the information therein is not disclosed accidently.
8.19 It should be noted that the submission of a report to the NCA is not intended to be used as a way to obtain information from law enforcement in order to assist the nominated officer in deciding whether to continue with the business relationship with the customer, nor should the absence of a response or feedback from the NCA be taken to imply that the casino operator should continue with the business relationship until adverse information about the customer is received from the NCA or other law enforcement agency.
Next chapter: External reporting