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On October 19, the Financial Crimes Enforcement Network (FinCEN) issued a notice that grants limited exceptive relief to casinos from some customer identity verification requirements regarding online gaming. Casinos are not subject to Customer Identification Program (CIP) regulations, which results in casinos not having the ability to rely upon non-documentary verification of a customer’s identity. As previously covered by InfoBytes, in 2020, FinCEN issued an interagency order granting an exemption from the requirements of the CIP rules for insurance premium finance loans extended by banks to all customers. According to the recent notice, a casino can use suitable non-documentary methods to verify online customers’ identification and “[t]he suitability or non-suitability of any particular method should be evaluated based on risk.” The notice also notes that a casino’s anti-money laundering program requires describing when the casino will verify identity by documentary methods, non-documentary methods, or a combination of both. This exceptive relief is effective October 19.
- Buckley Webcast: Privacy and cybersecurity outlook for 2022
- Jonice Gray Tucker to discuss “Be Your Compliance Best in 2022” at the California Mortgage Bankers Association webinar
- Hank Asbill to discuss white collar ethics issues at the Stetson Law Review Symposium
- Lauren R. Randell to discuss “Significant legal developments in the Northeast” at the 37th Annual National Institute on White Collar Crime
- Jonice Gray Tucker to discuss “Small business & regulation: How fair lending has evolved & where it is heading?” at the Consumer Bankers Association Live program
- Jonice Gray Tucker to discuss “Regulators always ring twice: Responding to a government request” at ALM Legalweek
- Max Bonici to discuss “Fintech-bank partnerships and potential enforcement” at the 2022 ABA Spring Meetings
- Jonice Gray Tucker and Kari Hall to discuss “Equity, equality, regulation and enforcement – The evolving regulatory landscape of fair lending, redlining, and UDAAP” at the ABA Business Law Committee Hybrid Spring Meeting