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Guidance

The prevention of money laundering and combating the financing of terrorism

Guidance for remote and non-remote casinos: fifth edition

6 - Ongoing monitoring

The Regulations require casino operators to conduct ongoing monitoring of a business relationship.

This must include the following:

  • 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
  • undertaking reviews of existing records and keeping the documents or information obtained for the purpose of applying CDD measures up-to-date.91

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.

References

91Regulation 28(11).

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Timing of verification
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Enhanced customer due diligence and enhanced ongoing monitoring
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