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Some of our customers have video poker machines or other gaming systems on their premises. Are there any BSA/AML issues we should be aware of? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Some of our customers have video poker machines or other gaming systems on their premises. Are there any BSA/AML issues we should be aware of?

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A customer that operates a video poker game will require some extra attention. We recommend monitoring the customer for compliance with the registration requirements and many other requirements in the Video Gaming Act, 230 ILCS 40, and in the Illinois Gaming Board’s regulations, 11 Ill. Adm. Code 1800. For example, Illinois law requires video game terminal operators to deposit revenues into “a specially created, separate bank account,” for making electronic tax payments. 230 ILCS 40/60(c)11 Ill. Adm. Code 1800.250(i). The Illinois Gaming Board has posted a plethora of information on its Video Gaming Page, including FAQs and a list of municipalities permitting video gaming.

Further, note that the FFIEC’s 2005 “Money Laundering Threat Assessment” publication identified video poker games as susceptible to use by criminal money launderers. According to the FFIEC, criminals “laundered money through video poker games by feeding illicit proceeds into the machines (one, five, and ten dollar bills) and then either after playing briefly or not at all, they pressed the ‘cash out’ button which generated a receipt that was redeemed for a casino check” (printed page 52, or page 66 of the PDF).