Casinos are by nature cash-intensive businesses undertaking various financial activities. The exchange of large amounts of cash makes casinos particularly vulnerable to money laundering activities.

Casinos are required to have an effective Anti-money laundering programme in place which must include procedures for detecting and reporting suspicious activities and transactions. It is also a requirement for the casino to implement effective customer identification and record-keeping procedures. The Centre views the membership subscription of clients to loyalty programmes offered by casinos as the establishment of a business relationship with such clients. Accordingly, these clients must be identified and verified, and records must be kept of any documents obtained to carry out this function, in accordance with the relevant provisions of the FIC Act and the Regulations.

A qualified individual who is responsible for the overall compliance function should be appointed and client-facing staff should receive adequate training on applicable laws, policies and procedures. Staff should also be properly trained on how to recognise transactions that appear to have no legitimate business purpose or are inconsistent with the players’ usual gaming activities.

The National Gambling Board (NGB) is responsible for the oversight of the regulation in the gambling industry throughout South Africa. The information and documents provided are specifically intended for gambling and casino businesses operating within South Africa.

Accountable institutions which fall under the National Gambling Board include any person who carries on a business in respect of which a gambling license is required to be issued by a provincial licensing authority. Casinos are accountable institutions in terms of item 39 of Schedule 1 to the FIC Act and must comply with the relevant provisions of the FIC Act and the Regulations to the FIC Act.