The prevention of money laundering and combating the financing of terrorism
5 - Supporting records (non-remote casinos)
The requirement to keep supporting records is linked to 'business relationships', which is defined in the Regulations 142 and the extent and nature of the records created. In many casinos, customers (regardless of whether or not they have formed a business relationship) purchase chips with cash at gaming tables where, in low risk situations, no records are created and therefore are not available to be kept.
The Commission expects casino operators to use reasonable endeavours to create and keep supporting records and to make it clear in their policies, procedures and controls what records will be created in light of the known spending patterns and the assessed money laundering and terrorist financing risks at each premises.
Some casinos undertake a process at the end of each business day to count the total drop (cash used to purchase chips) to compare against the total amount recorded through tracking individual customer spend. The difference between the two figures is the amount of drop that is not attributable to particular customers. This in turn can be calculated against known attendance figures and the number of customers tracked to give an average amount of money used to purchase chips per customer that has not been tracked, and therefore without supporting records. Where this process is used, it should be the subject of ongoing risk assessment for each premises and the records created during the process should also be retained.
Any casino operator devising its record-keeping policy and procedure should decide how its business fits within the definition of 'business relationship'. The variation in the record-keeping requirements for different circumstances illustrates the flexibility available to casinos which allows them to focus their resources on situations with higher money laundering or terrorist financing risk.
For the purposes of supporting records, the Commission takes the view that, in most cases, this will consist of records covering the drop/win figures, subject to the requirements outlines for other casino customers for each customer. There is no requirement to keep detailed records for each customer for each table or game for AML purposes. However, HMRC may require casino operators to maintain records for each table or game, but not broken down by each customer’s transactions.
142 Regulations 3 and 4.
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Supporting records (remote casinos)
Last updated: 12 November 2020
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