14. Enhanced customer due diligence for higher‑risk patrons

A casino operator must implement appropriate policies, controls and procedures to determine if a patron, or a beneficial owner of a patron account, is a higher‑risk patron.

Subject to this regulation, a casino operator must, in addition to the customer due diligence measures prescribed in this Part, perform enhanced customer due diligence measures in relation to higher‑risk patrons, including the following measures:

establishing by reasonable means, and verifying using reliable and independent sources, the source of wealth and source of funds of a higher-risk patron;

requiring that prior approval be obtained from an employee holding a senior managerial or executive position in the casino operator based on the information mentioned in sub-paragraph (a) before establishing dealings with a higher-risk patron, or before continuing dealings with a patron (or a beneficial owner of a patron account) who subsequently becomes a higher-risk patron;

conducting ongoing monitoring in respect of a higher-risk patron and where any change in the patron’s risk profile exceeding the thresholds of materiality and thresholds of risk established under regulation 17(4)(a) is detected, to reassess the approval obtained under sub-paragraph (b) and update the casino operator’s records about the patron mentioned in paragraph (1B);

conducting such enhanced monitoring of the transactions of the higher‑risk patron as the casino operator considers appropriate having regard to the thresholds of materiality and thresholds of risk established under regulation 17(4)(a), which may include —

increasing the number of controls applied;

shortening the intervals between the application of controls; and

identifying and examining patterns of transactions or unusual transactions.

The casino operator must, at the minimum, keep the following records in respect of every transaction entered into, and every patron account opened, by a higher‑risk patron:

the identifying information of the higher‑risk patron;

the date, amount and type of transaction;

the name, special employee licence number and signature of the authorised employee who carried out the transaction;

the source of wealth and source of funds of the higher‑risk patron;

the name, special employee licence number and signature of each authorised employee designated by the management of the casino operator to approve the establishment of dealings with the higher‑risk patron or the carrying out of the transaction.

The casino operator shall keep a record in writing of its findings and decisions in relation to the matters in paragraphs (1) and (1A), which shall be produced to the Authority or to a Suspicious Transaction Reporting Officer on demand.

A casino operator may adopt a risk-based approach in determining whether to perform the enhanced customer due diligence measures mentioned in paragraph (1A) or the extent of the enhanced customer due diligence measures to be performed for any or all of the following politically-exposed persons:

an individual who has been entrusted with any prominent public function in Singapore, or an immediate family member or close associate (in a personal or professional capacity) of that individual;

an individual who has been entrusted with any prominent public function by an international organisation, or an immediate family member or close associate (in a personal or professional capacity) of that individual;

an individual who has stepped down from his or her prominent public function, taking into consideration the level of influence the individual may continue to exercise after stepping down from such prominent public function, or an immediate family member or close associate (in a personal or professional capacity) of that individual.

Paragraph (3) does not apply where the politically-exposed person’s dealings or transactions with the casino operator present a high risk of money laundering, terrorism financing or proliferation financing.

Despite paragraph (1A)(a) and (b) and subject to paragraphs (6), (7) and (8), a casino operator may establish dealings with a higher-risk patron or continue dealings with a patron (or a beneficial owner of a patron account) who subsequently becomes a higher-risk patron before completing the verification mentioned in paragraph (1A)(a) if —

the deferral of completion of the verification is essential in order not to interrupt the normal conduct of business operations;

the risks of money laundering, terrorism financing and proliferation financing can be effectively managed by the casino operator; and

prior approval is obtained from an employee holding a senior managerial or executive position in the casino operator to so establish or continue dealings (as the case may be) before completing the verification.

Where paragraph (5) applies, the casino operator must —

adopt internal risk management policies and procedures concerning the conditions under which the casino operator may so establish or continue dealings before completing the verification mentioned in paragraph (1A)(a); and

subject to paragraph (7), complete the verification within the applicable time specified in the Code.

Where the casino operator is unable to complete the verification within the applicable time specified in the Code as mentioned in paragraph (6)(b), the casino operator must stop its dealings with the higher-risk patron after that time, until the casino operator completes the verification.

Where verification has been carried out under paragraph (6) or (7), the casino operator must not continue or resume dealings with the higher-risk patron after completion of the verification unless the approval of an employee holding a senior managerial or executive position in the casino operator to do so has been obtained taking into account the source of wealth and source of funds of the higher-risk patron as verified.

A casino operator must implement appropriate policies, controls and procedures to determine if a patron, or a beneficial owner of a patron account, is a higher‑risk patron.

Subject to this regulation, a casino operator must, in addition to the customer due diligence measures prescribed in this Part, perform enhanced customer due diligence measures in relation to higher‑risk patrons, including the following measures:

establishing by reasonable means, and verifying using reliable and independent sources, the source of wealth and source of funds of a higher-risk patron;

requiring that prior approval be obtained from an employee holding a senior managerial or executive position in the casino operator based on the information mentioned in sub-paragraph (a) before establishing dealings with a higher-risk patron, or before continuing dealings with a patron (or a beneficial owner of a patron account) who subsequently becomes a higher-risk patron;

conducting ongoing monitoring in respect of a higher-risk patron and where any change in the patron’s risk profile exceeding the thresholds of materiality and thresholds of risk established under regulation 17(4)(a) is detected, to reassess the approval obtained under sub-paragraph (b) and update the casino operator’s records about the patron mentioned in paragraph (1B);

conducting such enhanced monitoring of the transactions of the higher‑risk patron as the casino operator considers appropriate having regard to the thresholds of materiality and thresholds of risk established under regulation 17(4)(a), which may include —

increasing the number of controls applied;

shortening the intervals between the application of controls; and

identifying and examining patterns of transactions or unusual transactions.

The casino operator must, at the minimum, keep the following records in respect of every transaction entered into, and every patron account opened, by a higher‑risk patron:

the identifying information of the higher‑risk patron;

the date, amount and type of transaction;

the name, special employee licence number and signature of the authorised employee who carried out the transaction;

the source of wealth and source of funds of the higher‑risk patron;

the name, special employee licence number and signature of each authorised employee designated by the management of the casino operator to approve the establishment of dealings with the higher‑risk patron or the carrying out of the transaction.

The casino operator shall keep a record in writing of its findings and decisions in relation to the matters in paragraphs (1) and (1A), which shall be produced to the Authority or to a Suspicious Transaction Reporting Officer on demand.

A casino operator may adopt a risk-based approach in determining whether to perform the enhanced customer due diligence measures mentioned in paragraph (1A) or the extent of the enhanced customer due diligence measures to be performed for any or all of the following politically-exposed persons:

an individual who has been entrusted with any prominent public function in Singapore, or an immediate family member or close associate (in a personal or professional capacity) of that individual;

an individual who has been entrusted with any prominent public function by an international organisation, or an immediate family member or close associate (in a personal or professional capacity) of that individual;

an individual who has stepped down from his or her prominent public function, taking into consideration the level of influence the individual may continue to exercise after stepping down from such prominent public function, or an immediate family member or close associate (in a personal or professional capacity) of that individual.

Paragraph (3) does not apply where the politically-exposed person’s dealings or transactions with the casino operator present a high risk of money laundering, terrorism financing or proliferation financing.

Despite paragraph (1A)(a) and (b) and subject to paragraphs (6), (7) and (8), a casino operator may establish dealings with a higher-risk patron or continue dealings with a patron (or a beneficial owner of a patron account) who subsequently becomes a higher-risk patron before completing the verification mentioned in paragraph (1A)(a) if —

the deferral of completion of the verification is essential in order not to interrupt the normal conduct of business operations;

the risks of money laundering, terrorism financing and proliferation financing can be effectively managed by the casino operator; and

prior approval is obtained from an employee holding a senior managerial or executive position in the casino operator to so establish or continue dealings (as the case may be) before completing the verification.

Where paragraph (5) applies, the casino operator must —

adopt internal risk management policies and procedures concerning the conditions under which the casino operator may so establish or continue dealings before completing the verification mentioned in paragraph (1A)(a); and

subject to paragraph (7), complete the verification within the applicable time specified in the Code.

Where the casino operator is unable to complete the verification within the applicable time specified in the Code as mentioned in paragraph (6)(b), the casino operator must stop its dealings with the higher-risk patron after that time, until the casino operator completes the verification.

Where verification has been carried out under paragraph (6) or (7), the casino operator must not continue or resume dealings with the higher-risk patron after completion of the verification unless the approval of an employee holding a senior managerial or executive position in the casino operator to do so has been obtained taking into account the source of wealth and source of funds of the higher-risk patron as verified.