Congress continues to debate the issue of Internet gambling. Nevertheless, Regulation GG is still on the books and compliance is mandatory on December 1. Banks planning to assemble a compliance effort now have a short time to act.
Regulation GG and a parallel set of regulations from the Department of Treasury implement and interpret the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA). The regulations took effect on January 19, 2009 and compliance is mandatory on December 1, 2009.
Why Participate?
The law and regulations require every bank to develop policies reasonably designed to identify and block or otherwise prevent restricted transactions. Compliance will be reviewed in on-site examinations by federal functional regulatory agencies. The compliance mechanisms are to focus on deposit activity in connection with commercial accounts. The ACH, card, check collection and wire transfer systems are all affected and each requires relevant policies and procedures.
Highlights
- Commercial accounts and unlawful Internet gambling
- Consumer accounts and unlawful Internet gambling
- Developing policies related to Internet gambling
- Customers that present a minimal risk of engaging in an Internet gambling business
- Due diligence for new customers
- Due diligence for existing customers
- Documenting legal Internet gambling
- Developing procedures for dealing with illegal Internet gambling
- Triggers for suspicious activity reporting
Sample Policies & Procedures
Materials include sample policies and procedures. They are not "one size fits all" examples that every financial institution can adopt. They are teaching tools intended to illustrate that the bank must consider a number of elements in the design of its internal documents. (Attendees at Ken's webinars are always very complimentary of the sample documents and language he includes in his materials.)
Presenter
Ken Golliher is a principal with Pegasus Educational Services, LLC. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. Prior to becoming a full-time trainer, Ken was a community banker and General Counsel for a regional consulting firm for financial institutions. He presents schools and seminars in over 25 states and has served on Compliance Schools sponsored by the OTS and the FDIC.
Audience
Expected attendees are officers and auditors employed by banks and thrifts who are responsible for building or evaluating a Regulation GG compliance structure. Depending on where these compliance responsibilities rest in your institution, those who should attend might be the compliance officer, security officer, BSA Officer, or auditor.
