On 10/19/21, FinCEN announced that it had granted limited exceptive relief (FIN-2021-R001) to casinos from certain customer identity verification requirements in the context of online gaming. Specifically, the relief allows a casino to utilize suitable non-documentary methods to verify the identity of online customers, though the suitability or non-suitability of any particular method must be evaluated based on risk.

The full FinCEN exemptive relief FIN-2021-R001 can be found at:

https://www.fincen.gov/sites/default/files/2021-10/Casino%20Exceptive%20Relief%20101921_0.pdf

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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