Brasilian Casinos Anti Money laundering Key Issues

By Federico Lannes ( International Gaming Consultant)

Federal Brasilian Government oversight in games of chance

Regarding the bill of law projects under sutdy, all types of Fortune games
should be submitted to the Federal government for approval. With exclusively
rights for: regulate license conditions, services, deployment and operation of
games of fortune in all its forms.
The states and municipalities can licences bingo halls and jogo do bicho
gaming whose operation has already been licensed by the the Federal
Government. Casinos are exlusively licensed by federal government by the
public bidding competition system.
It its forseen that the states and municipalities will have low AML and
compliance powers oversight.
The legislative draft entitles the Brasilian Union the creation of a Federal
Agency for for the regulation and supervision of games of chance activity in
Brazil. It is not defined which attributes will it have, in accordance with the law
of fortune games (gambling) throughout the Brazilian territory.
The legislative projects considers transparency, a Foundation value in this
industry. We remark the legal / regulatory environment where transparency
rules and guidance provide certainty to business and authority effective
implementation to achieve the objectives of the framework compliance
framework.

Preventing and combating money laundering crimes or concealment of

assets
The bill of law projects under study considers:
Mandatory to companies licensed to exploit fortune games on national
territory the usage of a Control Management System (CMS) in order to
allow Union entities to monitor bets and prizes payment in each of its
modalities.
For any game of chance, the operator, should report to the Federal
Executive Branch, information about players who bet or receive awards
in amounts exceeding R$ 10,000.00 (USD 3.100) at once.
These players should be properly identified and registered, including the
name, address and number of individual registration (CPF), together the
tax authority.
Regarding the granting of licenses for Casinos, Federal Government will
take into account between commitment purpose of compliance with
corporate governance standards and implementation of effective
 mechanisms to prevent fraud and money laundering for both the legal
entity, partners and directors and managers.
The National Government will, create an agency responsible for the
regulation and supervision of games of chance activity in Brazil

We see that AML (Anti Money Laundering) preventive measures in these

legislative projects are basic and limited to general provisions. But should be
equally important to include other issues on the regulatory decree as follow:
Developing a compliance program to detect money lanundering and
terrorist financing.
Identify any beneficial owner (i.e. the natural person(s) who ultimately
owns or controls a customer and/or the person on whose behalf a
transaction is being conducted.
The bill of law projects thresholds applies only to single transaction, not
to several transactions that appear to be linked of a same player in a
certain period of time.
Policy about Customers that are Politically Exposed Persons (PEPs).
Customer identification, and record keeping information
Transaction monitoring and alert / A reporting entity must put in place a
transaction monitoring and alert program.
Reporting of suspicious activity to competent authorities in accordance
with the Anti-Money Laundering Policy and applicable laws, rules and
regulations
Policies about proper staff training and their obligations under the
AML/CTF Act and Rules
Establishment of a compliance department and a head of compliance
who will be the liason between the Federal authorities and the company.

The AML- Program has been defined by the Consortium as a high priority and
help to minimize the gaming operators risks associated and to ensure a robust
compliance culture in the entire organization setting the tone at the top with
the board of directors.
We believe that compliance is the responsibility of everyone in the organization
and we help on the training process of employees and managers to adhere to
high standards and to stringently maintain the regulations on matters of
compliance.
We conduct risk management assessments, independent compliance reviews,
and legal advisory to provide guidance and ensure that all departments and
businesses to comply with the AML/CFT Compliance Program. We also advise
boards and senior management to develop compliance and ethics programs as
recommended based on our experience on different countries in latinamerica.
The member of the consortium The Innovation group Michael, Soll,
International Gaming Consultant Federico Lannes and Edgar Lenzi from
Betconsult will be attending the 3rd Brasilian Gaming Congress as speakers
which will be held on november 20 to 22, 2016.