Vetting of High Rollers
by Christine Duhaime, BA, JD, Certified Financial Crime and Anti-Money Laundering Law Specialist
According to Reuters, FinCEN is amending anti-money laundering (AML) policies to require that casinos ascertain source of funds for large cash or wire deposits, or large bets in the United States. Before such a move takes place, FinCEN would submit the proposed rule for comment by the industry.
Any commentary that opposed the change, however, is unlikely to be considered seriously because source of funds vertification already exists for politically exposed persons in AML law in most countries, including in the US. It is also routinely done for immigration purposes in many countries with investor immigration programs that encourage immigration from Asia. Such a rule would not be any more burdensome or expensive in terms of compliance for casinos, than it is for other sectors that report to FinCEN.
When such a rule is implemented, however,it will negativey impact the appeal of gambling in the US by Asian tourists who, as a matter of culture, will be reluctant to disclose personal information to any casino operator, particularly financial information and particularly in the gaming environment when such information will be provided to gambling regulators and FinCEN.