TEAM HERALD
teamherald@herald-goa.com
PANJIM: In an interesting development, the State government has notified the anti money laundering and financing of terrorism guidelines 2013 by which casinos will be covered under the category of financial institutions and liable to responsibilities of knowing their customers who gamble therein.
Every casino has to henceforth prepare its Know Your Customer (KYC)/Anti Money Laundering/Combating Financing of Terrorism Policy and procedures aimed at preventing and detecting money laundering and terrorist financing.
The rules require appointment of a person as Principal Officer by each casino from among its senior management. This officer will have to act as a central reference point of the casino and report particulars of customers to the Financial Intelligence Unit, India. He/she shall also be responsible for monitoring and reporting of all transactions and sharing of information as required under the law. The Principal Officer will have to ensure that the obligations under the Act and Rules are fulfilled.
The guidelines also demand timely access to customer identification data and other Customer Due Diligence information, transaction records and other relevant information.
It has been pointed out that many casinos offer deposit accounts and lines of credit with less scrutiny and Customer Due Diligence (CDD) requirements than financial institutions.
Casinos will have to have an ongoing employee training programme so that the members of the staff are adequately trained in Know Your Customer procedures. Casinos shall also establish ongoing employee training to ensure that employees are kept informed of new developments, including information on current Money Laundering and Financing of Terrorism techniques, methods and trends and that there
is a clear explanation of all aspects of Anti Money Laundering/Combating Financing of Terrorism laws and obligations, and in particular, requirements concerning Customer Due Diligence and suspicious transaction reporting.
As per the guidelines, casinos will also have to pay special attention to all complex, unusual, large transactions and all unusual patterns of transactions, which have no apparent economic or visible lawful purpose.
The casinos have to maintain the background including all documents/office records/memorandums pertaining to such transactions which need to be maintained for a 10 years. The guidelines also mandate that casinos shall not accept a customer where it is unable to apply appropriate customer due diligence measures i.e. the casino is unable to verify the identity and or obtain documents required as per the risk categorisation due to customer’s non co-operation.
