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