Financial Crime World

Anti-Money Laundering and Anti-Terrorist Financing Regulations 2008: Key Points on Verification Timing

General Requirements

To ensure compliance with anti-money laundering and anti-terrorist financing regulations, relevant persons must verify the identity of customers (and any beneficial owners) before establishing a business relationship or carrying out an occasional transaction.

  • Verification at Establishment: Verification can be completed during the establishment of a business relationship.
  • Verification after Establishment: Verification can also take place after the business relationship has been established, if necessary to manage risks.
  • Later-Stage Verification: In some cases, verification may need to occur at a later stage if there is a change in risk assessment.

Exceptions and Special Cases

While general requirements apply, there are exceptions and special cases that warrant consideration:

  • Life Insurance Policies and Trusts: Verification may take place after the business relationship has been established but before payout or when the beneficiary exercises their rights.
  • Account Holders: Verification can occur after the account has been opened, provided there are adequate safeguards in place to prevent unauthorized transactions.

Casino-Specific Requirements

Casino operators must establish and verify the identity of patrons who:

  • Use gaming facilities
  • Purchase or exchange chips with a total value of $3,000 or more within 24 hours
  • Pay the casino $3,000 or more for the use of gaming machines

Patron Accounts

To maintain compliance, casino operators must adhere to the following rules regarding patron accounts:

  • Anonymous Accounts: No anonymous patron accounts should be opened or maintained.
  • Account Opening: Patron accounts can only be opened in the name of a natural person.
  • Identity Verification: The identity of each patron opening an account must be verified using reliable and independent sources.

Please note that these summaries are for general guidance. It’s essential to consult the actual regulations for specific requirements and implementation details.