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Casinos warned to monitor customers’ fund sources

The chief of U.S. Treasury’s anti-money laundering unit said casinos must use all information at their disposal to uncover suspicious customer transactions, including information about their source of funds.

In her keynote address at a conference Thursday in Las Vegas, Jennifer Shasky Calvery, director of Treasury’s Financial Crimes Enforcement Network (FinCEN), said regulations require casinos to use “all of the information available to them in investigating suspicious transactions.”

“FinCEN expects that casinos, like other financial institutions, inquire about the source of funds as appropriate under a risk-based approach,” she said.

Shasky Calvery said casino customers who transfer large sums of money from “jurisdictions reported to have high crime or corruption” would be prime candidates for source-of-funds reviews. She used Macau as an example.

“Under a risk-based approach, these situations represent times when you may need to learn more about your customer and his or her source of wealth to identify suspicious activity,” she said.

In a September speech she gave at the Global Gaming Expo in Las Vegas, Shasky Calvery said some in the casino industry hadn’t done enough to combat money laundering. 

When some casinos say that “probing their customers about their activities outside of the casino will drive customers away, I sense that they feel that it is not their responsibility to protect their institutions, and our financial system as a whole,” she said.

On Thursday, Shasky Calvery again emphasized cainsos’ ongoing obligation to use their surveillance systems and compliance programs to detect and prevent money-laundering.

To create a cultures of compliance, she said, “casinos must insure that all customer information gets to the right people in their compliance unit.”

In March 2007, Mexican police raided the home of a casino customer named Zhenli Ye Gon in Mexico City. They seized $207 million in cash from the Shanghai-born, high-stakes gambler who became a Mexican citizen in 2002.

Until then, no one at the Venetian-Palazzo or the Las Vegas Sands Corp had identified Ye Gon’s financial transactions as “suspicious.”


Julie DiMauro is the executive editor of FCPA Blog and can be reached here.

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