THE B.C. Lottery Corporation has implemented the first of Peter German’s interim recommendations, through new procedures requiring service providers to gather detailed information on the source of player funds for all transactions of $10,000 or more.
Effective January 10, all cash and bank draft / certified cheque buy-ins for $10,000 or more, in one or more transactions within a 24-hour period, will require a source of funds receipt. The original receipt must be from the same day of the transaction and show the financial institution, branch number and account number. This information will be required before a customer is allowed to buy in and will be reviewed daily by BCLC’s Anti-Money Laundering (AML) unit.
The casino service providers’ registered gaming worker conducting the transaction at the cash cage will be required to certify that he or she received a source of funds declaration directly from the customer, and completely and accurately recorded that information. In addition, the customer will be required to sign the source of funds declaration form.
If a customer does not provide the required information, provides information that is clearly suspicious or refuses to sign the source of funds declaration, service providers must refuse the transaction, document the refusal, and notify BCLC, which will trigger an investigation.
BCLC says that it has always required service providers to obtain and record detailed identification information on all customers who buy-in with cash of $10,000 or more. In addition, source of funds information was required in many other circumstances. The expanded source of funds procedures are in direct response to Peter German’s December 5, 2017 interim recommendation, prior to delivering his full report on anti-money laundering in Lower Mainland casinos to B.C.’s Attorney General by March 31, 2018:
“Service Providers must complete a Source of Funds Declaration for cash deposits or monetary instruments of $10,000 or more. At a minimum, the declaration must outline a customer’s identification and provide the source of their funds, including the financial institution and account from which the cash or instrument was sourced. After two consecutive transactions, cash can only be accepted from the customer once it has been determined that it is not of a suspicious or illegal nature.”
BCLC says it will support GPEB as requested and needed with respect to German’s second interim recommendation wherein GPEB investigators should be present in high-volume casinos in the Lower Mainland on a 24/7 basis.