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.

If you don't have experience with this type of account, I would pass.

Agree. We would decline.

We would also pass on this one.

Thanks for all your replies. Would anyone from BOL like to weigh in on this topic?

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?

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.