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#2202265 - 01/08/19 12:46 PM Professional Poker Player and LLC
downbytheriver Offline
Member
Joined: Jan 2008
Posts: 51
Georgia
We have a person who has approached our bank to open an LLC account for his professional gambling purposes. We've never opened these types of accounts before so could someone help me out with how to effectively monitor such an account? What are the types of red flags we should be looking for? I know they would be higher risk but how would be determine legitimate gambling activity from illegitimate?

Thanks in advance for your help.

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#2202358 - 01/08/19 07:47 PM Re: Professional Poker Player and LLC downbytheriver
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,258
If you don't have experience with this type of account, I would pass.
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CRCM, CAMS

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#2202390 - 01/08/19 10:55 PM Re: Professional Poker Player and LLC downbytheriver
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 1,996
The West
Agree. We would decline.
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TryingToComply
CRCM

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#2202394 - 01/08/19 11:35 PM Re: Professional Poker Player and LLC downbytheriver
Buddy the Elf Offline
Platinum Poster
Buddy the Elf
Joined: May 2002
Posts: 973
first lily pad on the right
We would also pass on this one.
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CAMS

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#2203252 - 01/17/19 12:49 PM Re: Professional Poker Player and LLC downbytheriver
downbytheriver Offline
Member
Joined: Jan 2008
Posts: 51
Georgia
Thanks for all your replies. Would anyone from BOL like to weigh in on this topic?

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#2203294 - 01/17/19 04:52 PM Re: Professional Poker Player and LLC downbytheriver
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,602
Pulling people out of the ditc...
what is your projected revenue for this one customer? what is your cost for continuous monitoring? after subtracting the 2nd from the 1st, does the bank make enough money to make this worth while to pursue?
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Providing alternative truths since the invention of time

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#2203301 - 01/17/19 05:26 PM Re: Professional Poker Player and LLC downbytheriver
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,643
I think that what the others are trying to say is that most of us don't have much experience with this type of account as for most, the risk and cost of managing the account would outweigh the benefits.

That said, if management forced this account on me (which could be the case for you), then (off the top of my head) here are some things you might consider:

- What type of activities would occur in the account? Based on this, would it be beneficial to establish separate accounts so that different activities could be viewed/reviewed in a silo?
- What are the projected sources of income from the LLC? Is this person on a professional gambling circuit? If so, will you be able to dig into the applicable events to have an understanding that they are actually legal?
- Are there any required licenses by either the player or venue? If so, what licenses will be reviewed/verified?
- Will there be a way to track cash payouts? For example, will winners/prizes be publicly available so that you can have a paper trail for cash deposits?
- What do their financials look like? You may want past financials/tax returns so that you can compare current activity with prior activity.
- Does the addition of this account impact your overall risk-profile?
- Does the addition of this account warrant increase staff/resources?
- When will you need to get an attorney involved?

Again, this is just a quick brainstorm and I am sure there are more things I would consider if I were in your shoes.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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