Presumably then (1) the banking community will be able to satisfy themselves that the gaming enterprises whom they maybe taking on as clients will be in compliance with local and international money laundering laws and regulations to the satisfaction of local and global financial regulators.

(2) The web-shop bank client take-on process may include audited financial statements and a laundry list of due diligence including beneficial owners identification etc. will need to be completed. For foreign banks, it is more than likely that approvals will need to be made in Toronto.

(3) Other gambling affiliated or closely held businesses (and persons) such as lending and client accounts would also need to be in compliance with banking legislation (bank license?). What about the gambling houses international branches and subsidiaries in other Caribbean jurisdictions? Will these be regulated from the Bahamas?

(4) If accepted as clients, the banks will need to make themselves comfortable with the placement of large cash deposits into their institutions not only to their local satisfaction but also to the satisfaction of their head offices.

(5) Failure on any of these points could cause some reputational issues for the banks.

(6) Finally in order to avoid tax (VAT) leakage it will be important for all gambling proceeds (including cash) be deposited into the local banking system.

The Church has said no to gambling, the people by way of poll have said no to gambling, civil society have raised issues on its impact on the poor, statements from the banking community have raised concerns. However, the current administration tells us that all will be fine once the industry is legalized.

I think may warrant a Suspicious Transaction Report by BEC or BEC's Bankers under the Bahamian Money Laundering Laws and Guidelines.

Please remember however that under our legal system you are innocent until proven otherwise.

The link to the money laundering guidelines is as follows:

https://www.bahamas.gov.bs/wps/wcm/conn…

On large cash transactions the guidelines state in section 6.1 of a 90 guideline:

"There are three stages of laundering, which broadly speaking, occur in
sequence but often overlap.

6.1 I. .....In the case of many serious ....., the proceeds take the form of cash, which the ......wishes to place in the financial system. Placement may be achieved by a wide variety of means according to the opportunity afforded to and the ingenuity of the........., his advisers and network. Typically, it may include: -

• placing of cash on deposit at a bank (often intermingled with a
legitimate credit to obscure the audit trail), thus converting cash into a
readily recoverable debt; or

• physically moving cash between jurisdictions; or

• making loans in cash to businesses which seem to be legitimate or are
connected with legitimate businesses, thus also converting cash into
debt; or

• purchasing high-value goods for personal use or expensive presents to
reward existing or potential colleagues; or

• purchasing the services of high-value individuals; or

• purchasing negotiable assets in one-off transactions; or

• placing cash in the client account of a professional intermediary."

We have the laws, regulations, regulators and enforcement officers in place to review and ensure that this transaction was legitimate.