The prevention of money laundering and combating the financing of terrorism
2 - Business relationships
A business relationship is a business, professional or commercial relationship between a casino operator and a customer which arises out of the business of the casino operator and is expected by the operator, at the time when the contact is established, to have an element of duration. 138 Casino operators are advised to interpret this definition widely.
A business relationship with a customer of a casino operator is likely to occur when, for example:
- a customer opens an account with the casino operator or becomes a member of a casino (when a membership scheme is operated by the casino), or
- a customer obtains a cheque cashing facility
- may occur when, for example:
- the casino starts tracking a customer's drop/win figures, other than to establish when the customer triggers the €2,000 threshold for CDD.
The list above is not exhaustive and a casino operator will need to form its own view of when contact is established, or circumstances otherwise arise, with a customer from which it expects, or it could reasonably be inferred that it expects, that the relationship with the customer will have an element of duration. The Commission accepts that this may not necessarily be the case when a casino operator permits a customer to join a casino loyalty scheme.
Ongoing monitoring of business relationships is a requirement for casino operators, and includes scrutiny of transactions undertaken throughout the course of the relationship (including, where necessary, the source of funds) to ensure that the transactions are consistent with the casino’s knowledge of the customer, the customer’s business and risk profile. 139
As noted in ongoing monitoring, casinos are expected to approach this requirement on a risk-sensitive basis. Dependent on how frequently a casino forms 'business relationships' it may be good practice to apply ongoing monitoring more widely. Regular players should be the subject of closer scrutiny and their level of play should be assessed with reference to the information already known about them, and where necessary, additional information must be collected and retained about the source of their funds.
138 Regulation 4(1).
139 Regulation 28(11).
General legal and regulatory requirements Next section
Other casino customers
Last updated: 12 November 2020
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