The prevention of money laundering and combating the financing of terrorism
Guidance for remote and non-remote casinos: fifth edition
1 - General legal and regulatory requirements
This chapter provides guidance on appropriate record-keeping procedures required by the Regulations. The purpose of the record-keeping requirement is to ensure that there is an audit trail that could assist in any financial investigation by a law enforcement body. These records are also important when the Commission is conducting an investigation for compliance purposes.
The casino operator’s record-keeping policy and procedure should cover records in the following areas:
- details of how compliance has been monitored by the nominated officer
- delegation of AML/CTF tasks by the nominated officer
- nominated officer reports to senior management
- information or other material concerning possible money laundering or terrorist financing not acted upon by the nominated officer, with reasoning why no further action was taken
- customer identification and verification information
- supporting records in respect of business relationships
- employee training records
- internal and external SARs, including decisions and actions taken by the nominated officer
- contact between the nominated officer and law enforcement or the NCA, including records connected to requests for a defence (appropriate consent).
The policy and procedure for record keeping should also make provision for the retention of records held by an employee who leaves the business.
The record-keeping requirements for supporting records, that is, the records of ongoing transactions with a customer, are based on the nature of the relationship with that customer. There is either:
- no relationship, or
- a 'business relationship', depending on the circumstances.
Last updated: 10 November 2020
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