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As subject persons in terms of the Prevention of Money Laundering and Funding of Terrorism Regulations, gaming licensees are required to submit Suspicious Transaction Reports (STRs) to the Financial Intelligence Analysis Unit (FIAU). An STR is to be filed whenever knowledge or reasonable suspicion exists, that funds deposited in a gaming account are the proceeds of illegal activities or are related to terrorism funding. The FIAU has now published a Guidance Note to assist remote gaming operators in identifying the information and documentation that should be submitted with an STR.
These include:
- Status of the player account: active, suspended/blocked or closed as well as any balance held in the gaming account as at the date report is raised
- Value and volume of the transactions
- Unusual activities such as unexpected increases in the volume of the deposits, usage of prepaid cards to effect a consistent number of deposits
- Details of the credit card and bank accounts used
- A transaction history
- Copy of due diligence documents; and
- Nature of checks carried out.
These guidelines have been produced with aim of improving the quality of the intelligence gathered from the gaming licensees to be able to provide a faster and more effective response to any criminal activity detected.
The full Guidance Note can be downloaded from the following link: