Preventing Money Laundering

PREVENTING MONEY LAUNDERING

Holland Casino has a legal duty to prevent money laundering and acts in accordance with the Dutch Prevention of money laundering and the financing of terrorism act (Wwft). As soon as we have any doubts as to whether the money a guest is playing with is legal, we initiate an interview with the guest in question. Occasionally, we find that we cannot guarantee the origins of the money and the guest in question is then no longer welcome at our casinos.

Reporting unusual transactions

In the context of the Dutch Prevention of money-laundering and the financing of terrorism act (Wwft), we report – in accordance with the guidelines – the following matters to the Dutch Finance Intelligence Unit:

  • Suspicious transactions, which are also reported to the police or the public prosecutor’s office.
  • Bank /cash transactions and deposits of more than € 15,000.
  • Transactions with cheques or foreign currency of more than € 15,000.
  • Transactions that give rise to the suspicion that they could be related to money laundering or terrorism.

Training employees

We train our employees to recognise suspicious behaviour or suspicious situations (subjective reporting criteria). This could range from guests who ask to exchange small denomination banknotes for €500 banknotes, to guests that fall just short of the limit of € 15,000 with a number of small transactions and guests who have money that quite literally has a suspicious smell (of soil or weed) to it.

HOLLAND CASINO ANTI-MONEY LAUNDERING POLICY

Total of 1,127,000 guests

1.    PREVENTION OF GAMING WITH MONEY WITH ILLEGAL ORIGINS
Focus on the guest and their transactions in the casino
 
1a) NO RISK
Identification, verification, registration
 
1b) MEDIUM RISK
•    exchanging chips/money for large denomination banknotes without having played with same
•    wrongly claiming winnings
Client investigation
 
87 guests
 
1c) HIGH RISK
•    Doubts remain about the origins of the money and/or the motives of the guest
Additional client investigation
 
41 guests
 
1d) UNACCEPTABLE RISK
•    Origins of money unacceptable or untraceable, or guest’s refusal to cooperate in client investigation
No more access to our services
 
1.    PREVENTION OF CONVERSION OF ILLEGAL TO LEGAL MONEY
Responding to signs of money-laundering, labelling and following money flows and reporting unusual transactions (MOT). Number of MOT reports: 1998
 
2a) Reports to Dutch FIU
•    Unusual transactions within the meaning of the law (objective and subjective indicators by trained employees)
 
FIU: Dutch Financial Intelligence Unit    
 
2b) Transfer of winnings
•    In the case of winnings of € 15,000 or more (confirmed by video images and trained employees)
•    In the case of poker tournaments
•    In the case of jackpots
•    For safety reasons

Figures 2015