Guys and Dolls

One money laundering control is the $10,000 deposit rule.  One problem with dodgy large-scale sports betting is that large sums of cash change hands.

“Cantor’s Bet on Gambling Proves Risky,” Wall Street Journal, October 29, 2013, A1

Cantor Fitzgerald has a sports betting business.  Its “chief bookmaker” pled guilty to accepting illegal bets.  Cantor’s gaming business now being investigated by, among others, the New York City Police Department, the US Postal Inspection Service, the US Treasury Department’s Financial Crimes Enforcement Network, the Federal Reserve Board, and the Nevada Gaming Control Board.

Were you to enter such a business, would you establish rigorous controls to make sure bags of cash weren’t flowing around and that people were not using your business to launder money? Would this be on your list of risks? What information-related controls would you set up?


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Filed under Compliance, Controls, Culture, Governance, Internal controls, Requirements, Risk, Third parties, Use

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