Is an annual audit of Reg GG required? I recently attended a seminar where the speaker said it was, however I cannot find anything in the regulation or elsewhere that indicates an annual audit is required.

Thanks.

We don't require it... but what we do in general is as part of our CDD for all business customers we require them to sign the form saying they don't do internet gambling.

As I update my spreadsheets for BSA monitoring, I added a "reg GG" column and simply put Y or N if the customer has signed the form. Everybody says yes and our monthly and daily monitoring would quickly identify someone using their business account for internet gambling. So when the regulators come I print my list showing all my business customers have signed the Reg GG, I give them a handful (as many as requested) of my business due diligence worksheets... and they just cross check the two.

I haven't had or been asked to do more "auditing" then that for Reg GG and we just had Safety and Soundness and they had no problems with it.

Cheers!

Thanks so much for the reply and your comments.