- Joined
- May 8, 2018
- Location
- south east england
page 57, section 6 has caught my attention, the first part seems to back casumo's policy
at the point where the threshold is reached, remote casino operators should put all funds owed to the customer into an account (or equivalent) from which no withdrawals can be made
but the 2nd part doesn't
if CDD cannot be completed, then the operator must proceed in line with regulation 31(1)(c) and terminate the existing business relationship with the customer
if funds are to be repaid, then the amount repaid should consist of all funds owed to the customer at the point that the threshold was reached, plus all deposits made at that point and thereafter
funds should be refunded back to the originating account, and:
there should be appropriate risk mitigation
where it is suspected that the funds are the proceeds of crime, remote casino operators should submit SARs or seek a defence (appropriate consent) before refunding any of the funds
^^^^
I can't see anyway round this, it's clear in black and white, a remote casino cannot hold a player's funds indefinitely. common sense tells you it has to be this way, casinos are not a law unto themselves.
at the point where the threshold is reached, remote casino operators should put all funds owed to the customer into an account (or equivalent) from which no withdrawals can be made
but the 2nd part doesn't
if CDD cannot be completed, then the operator must proceed in line with regulation 31(1)(c) and terminate the existing business relationship with the customer
if funds are to be repaid, then the amount repaid should consist of all funds owed to the customer at the point that the threshold was reached, plus all deposits made at that point and thereafter
funds should be refunded back to the originating account, and:
there should be appropriate risk mitigation
where it is suspected that the funds are the proceeds of crime, remote casino operators should submit SARs or seek a defence (appropriate consent) before refunding any of the funds
^^^^
I can't see anyway round this, it's clear in black and white, a remote casino cannot hold a player's funds indefinitely. common sense tells you it has to be this way, casinos are not a law unto themselves.
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