Status Report of Dr. Peter German's Recommendations

3

That BCLC, in conjunction with the Regulator and Service Providers, review the present Source of Funds Declaration on at least an annual basis to determine if refinements are required.

4

That BCLC re-enforce the importance of Service Providers not accepting cash or other reportable instruments if they are not satisfied with a source of funds declaration.

Addressed

7

That BCLC provide Corporate Suspicious Transaction Reports (STRs) if its files contain relevant information not contained within an STR from a Service Provider.

Addressed*

10

That the Regulator / Designated Policing Unit be provided with access to iTRAK in its offices.

Addressed

11a

That Unusual Financial Transaction (UFT) reports be eliminated.

Addressed*

16

That BCLC not engage in further undercover operations, except in conjunction with the Regulator and/or the police.

Addressed

17

That no further expense be incurred by BCLC with respect to the SAS AML software system.

Addressed

18

That BCLC ensure VIP hosts do not handle cash or chips.

Addressed

21

That cash limits not be imposed on buy-ins.

Addressed

22

That PGF accounts be eliminated once responsibility for cash alternatives has transitioned to the service providers.

Note: This is dependent on completion of Recommendation 20: That cash alternatives become the responsibility of the Service Providers, subject to their compliance with overarching standards.

Addressed

23

That BCLC implement a chip tracking system for Service Providers.

Addressed

R0.1 Interim

Service Providers must complete a Source of Funds Declaration for cash deposits or monetary instruments of $10,000 or more. This includes the requirement for customers to provide evidence of the source of their buy-in funds.

Addressed