I work at an East Coast bank; it is my job to track and monitor our customers account activities. In the last several months one of my assignments is to monitor and document Internet gambling done by customers of our financial institution.
To the best of my knowledge regulators have not set specific guidelines in relation to enforcing the new internet gambling law. However, my bank has been taking a proactive approach. Anyone we find gambling online is contacted and they are informed about the new law passed by Congress. The Internet Gambling Enforcement Act was passed to “prevent the use of certain payment instruments, credit cards, and fund transfers for unlawful Internet gambling” (see H.R. 4411). We can only reject transactions if we have documentation; therefore I document known Internet gambling sites and Internet gambling facilitators. As the gambling site list is compiled, the sites are also added to our OFAC (Office of Foreign Assets Control) hit list. This way we receive an automatic notification if a customer is trying to use their account with a known gambling entity.
The process of compiling our blacklist of sites is on going. We actively search for new web sites that relate to or support Internet gambling. Some of these sites are found while our AML (Anti-Money Laundering) Investigators are reviewing accounts. When Internet gambling web sites show up on our customer’s accounts, we record the activity. Any new sites that are found are added to the list to help our investigators in the future; many of these web sites change names and payment centers quickly, which makes it tough to keep up with them. I also use gambling forums where people discuss how to avoid detection by the government. These forums help me find out what tactics they are using and it makes my job a lot easier.
I then create documentation (what we call a memo) with screen shots of these sites and of the information that connects them to Internet gambling. These memos are not extravagant, they just provide proof that the website helps to facilitate Internet gambling.
Once we record the activity, we tell the customer that if this activity continues we will be forced to close the account(s) and commit them to stop using their accounts with our bank for illegal Internet gambling. (After all, banking with our financial institution is a privilege not a right.) After the initial phone call, most people are scared straight, and stop the illegal activity.
Next we place their accounts in our logging system. Accounts then get a 2 week review; if activity continues then we start account closing procedures. This is a measure we take to protect the bank from future loss and/or regulation headaches. If the customer has discontinued using their accounts for online gambling then we annotate their account log until the next review.
The Banks’ current review schedule is two weeks, two months, six months, one year, than once annually. However, this is subject to change since the Regulators and Lawmakers have not fleshed everything out and we are still awaiting clear guidelines.
So…. that’s where we are at right now. Unfortunately, there are still quite a few people trying to use alternative methods to fund their gambling addiction; I just hope they continue to post the methods on forums to make my job easier.
David C.
