What every U.S. casino and card club must know about compliance with the Office of Foreign Assets Control (OFAC) regulations

Abstract

This article explores that although casinos and card clubs may not have known much about OFAC until this article, the economic sanctions administered by the agency likely will play a larger and more visible role as middle to large scale gambling establishments continue to conduct cross-border and global financial transactions with high-end gamblers from countries known for their lack of transparency. The way for casinos and card clubs to detect and deter customer criminal activity and terrorism, as well as potential civil and criminal penalties for non-compliance with OFAC requirements, is to have a comprehensive compliance program that includes: creation and retention of records, internal controls, testing, compliance personal, ongoing training, and use of computerized systems and programs. However, while bricks-and-mortar casinos and card clubs in the United States need to devise the means for identifying and controlling the risks associated with OFAC sanctions, the task is not an easy one. Also, for bricks-and-mortar casinos and card clubs that offer customer deposit and credit accounts, check cashing, and transmitting and receiving funds transfers directly from other financial institutions the process of due diligence to uncover individuals on a SDN List, or from a blocked country, needs to be a continuing effort of screening to ensure that these non-bank financial institutions do their part in this effort to support U.S. foreign policy, national security goals, and economic sanctions. (PsycInfo Database Record (c) 2021 APA, all rights reserved)