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Financial Services Law Insights and Observations


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  • FinCEN grants limited relief to casinos

    Financial Crimes

    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.

    Financial Crimes FinCEN Department of Treasury Anti-Money Laundering Customer Identification Program

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