CONFRONTING TODAY’S REALITIES IN THE
GAMING INDUSTRY
PRESENTER: BRIAN GEORGE, CHAIRMAN, JAMAICA GAMING ASSOCIATION (JGA)
BETTING GAMING & LOTTERIES COMMISSION (BGLC) SUMMIT - SEPTEMBER 22, 2016
THE DEVELOPMENT OF THE INDUSTRY:
‘FROM THE DAYS OF BUGSY SIEGEL’…
 Bugsy Siegel - A driving force behind the development of the Las Vegas Strip AND one of the most
infamous and feared gangsters of his day. He built an untouchable empire, utterly devoid of a
compliance and regulatory framework.
 Now, the Nevada Gaming Commission is perhaps the strictest that exists
….TO JA TODAY - INDUSTRY OVERVIEW
 An industry governed by strict compliance guidelines and measures having adopted the Gaming
Commission’s Fit and Proper Procedures. However, too many gaps still remain
 Some $57B in sales generated from 26 gaming lounges; declared gross profit of $3.423B
 Approximately 6,000 gaming machines
 Total Government Revenue – approximately $65M
*Source – BGLC Annual Report 2013-2014
A CHANGING INDUSTRY:
CFTAF – APPLICATION AND IMPLICATIONS
 CFATF - regional intergovernmental body established in 1992, responsible for ensuring that standards
relating to anti-money laundering and countering the financing of terrorism (“AML/CFT”) are
implemented and maintained across the Caribbean and Central American region; didn’t initially
apply to gaming but to banking; gaming industry didn’t play close attention to the realities
 Establishment/Enforcement of Minimum Standards in April 2016: that all appropriate steps regarding
knowledge of developments in money laundering; staff training; adoption of anti-money laundering
and terrorist financing policies; application of appropriate customer due diligence; report those who
engage in suspicious activities to the Financial Investigation Division (FID). Business compliance
based off meeting minimum standards, the BGLC Anti-Money Laundering Guidance Notes and the
provisions of the Proceeds of Crime (Money Laundering Prevention) Regulations, 2007.
CORRESPONDENT BANKING AND DEBANKING
 Effective April 2016, gamers have had to properly identify themselves – names, proper ID, references
- before they can gamble, same measures used when joining a bank. Main issue we now face:
Correspondent banking and the threat of de-banking
 Correspondent banks domiciled in the United States and the UK applying restrictions to regional
markets (particularly in the Caribbean and Central America) due to high risk and resultant high
penalties
 Current situation : Banks have already started to curtail involvement in our
industry because our risk profile is seemingly too great; if we have no banking
access, we have no industry
ROLE OF THE JAMAICA GAMING ASSOCIATION (JGA)
 Formed by the seven largest gaming lounge operations in Jamaica to work with the Betting Gaming
& Lotteries Commission (BGLC) towards practical implementation and oversight of new policies
geared towards the enhancement of the integrity of the industry, particularly in the areas of Anti
Money Laundering (AML) and the requirements under the Proceeds of Crime Act (POCA) ;
 To provide a platform for all operators in the Gaming Industry to have a coordinated voice on
matters affecting the industry;
 To work with relevant bodies such as RISE Life Management Services to ensure the widest
implementation of Responsible Gaming Principles and Practices, and identifying and promoting
policies which can stimulate the long-term growth, innovation and reinvestment in the industry by
its members.
MULTI-STAKEHOLDER APPROACH – ALL HANDS ON DECK!
 Avoiding de-banking requires a multi-stakeholder approach.
 COMPLIANCE IS NOT ONLY AN ISSUE FOR THE JGA AND GAMING ENTITIES; STRICT ENFORCEMENT BY
REGULATORS IS CRITICAL
 While gaming entities are responsible for ensuring that their businesses are not used by criminals to
launder the proceeds of their crimes, the BGLC has the ultimate responsibility to enforce regulations and
act to weed out non-compliant players with alacrity. This is critical for the industry’s survival. There is no
value in issuing a licence to an entity who is unbankable in its own jurisdiction.
 Government needs stronger push (back) on international platforms, including the Financial Action Task
Force (FATF), to highlight the danger to regional economies posed by
de-banking
WAY FORWARD
 Zero tolerance approach to non-compliance
 Greater Collaboration and Learning from Each Other
 More training and dialogue between stakeholders to take further steps to bridge gaps in
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compliance
Continued training of those within the sector and information dissemination for sectoral
development
Compliance and Enforcement!
Moving from ‘KYC’ to ‘KYCC’
Strong Government Lobby for an environment conducive to industry growth
Local and Int’l Banks evaluating on an ongoing basis. In the region, Jamaica can
help itself by establishing high standards of compliance; only protection against
being unbanked