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In the case of gambling casinos the requirement regarding identification referred to in this section shall apply to the following operations: 1. (...) Transfers of funds performed by casinos at the request of customers. 3. The issue by casinos of certificates attesting winnings obtained by players. (...) Without prejudice to the foregoing, gambling casinos shall in all cases notify the Executive Service of those operations which present evidence or certainty of a connection with money-laundering and take one of the forms described in paragraph (a) above.

The only figures encountered are estimates of the number of players in 1989: 21,000 addicts to gambling, 360,000 persons who play the fruit machine regularly, 440,000 persons who play the fruit machines incidentally, 400,000 persons who visit a casino incidentally, 200,000 bingo players (every now and then) and 5,300,000 players of the lotteries 9. (...) Adding something for the other players gives an estimate of the total revenues of 2,000 million. (...) The assumption that the average losses of the lottery players are 20 dfl per month is not based on solid information.

CONTENTS Page E/NL.2003/46 Regulations of the National Anti-Money-Laundering Network 2 E/NL.2003/47 National Commission on Casinos, Bingo Halls and Slot-Machines: Administrative Decision No. 5 6 - 2 - E/NL.2003/46-47 Page 2 REGULATIONS OF THE NATIONAL ANTI- MONEY-LAUNDERING NETWORK PREAMBLE Unlawful money-laundering operations are being carried out on an ever increasing scale and their perpetrators, whom nationality, sovereignty and national development fail to restrain, employ advanced technologies to achieve their aim, which is simply to legitimize the proceeds of various offences, including, naturally, money derived from the illicit sale or marketing of drugs. (...) - 6 - E/NL.2003/46-47 Page 6 OFFICIAL GAZETTE No. 37630 DATED 12 FEBRUARY 2003 ADMINISTRATIVE DECISION No. 5 CARACAS, 23 DECEMBER 2002 THE NATIONAL COMMISSION ON CASINOS, BINGO HALLS AND SLOT-MACHINES WHEREAS: In accordance with the provisions of article 3 of the Law on the Control of Casinos, Bingo Halls and Slot-Machines, this Commission is the body responsible for regulating activities under that Law; In accordance with the provisions of article 214 of the Narcotic Drugs and Psychotropic Substances Organizational Act,1 gaming enterprises are required to cooperate with the National Executive in the monitoring and control of sums of money or other property suspected of being directly or indirectly derived from offences established under that Act or from related activities; In accordance with the provisions of article 213 of the Narcotic Drugs and Psychotropic Substances Organizational Act, this Commission is required to lay down, within its sphere of responsibilities, preventive measures for countering at the national level the laundering of money and financial proceeds suspected of being derived from the commission of offences established under that Act; Article 4, paragraph 5, of the Regulations of the Law on the Control of Casinos, Bingo Halls and Slot-Machines empowers this Commission to lay down any rules that it considers necessary for the most effective application of that Law; HEREBY RULES AS FOLLOWS: Article 1: Shareholders of enterprises applying for licences to establish casinos or bingo halls shall be obliged to provide the following as essential requirements in addition to those laid down by the Law on the Control of Casinos, Bingo Halls and Slot-Machines and its Regulations: 1. (...) Article 3: The entities referred to in the preceding article shall submit reports on suspicious, unusual or unconventional activities to the National Commission on Casinos, Bingo Halls and Slot-Machines, which shall transmit such reports to the National Commission against Illicit Drug Use (CONACUID).

The CTC would like to point out that Casinos could offer an attractive venue for laundering illegal proceeds, as well as a possible source for financing terrorist activities. The CTC would therefore like to receive a detailed description of provisions in place, or under consideration, aimed at regulating and licensing the activities of Casinos. Furthermore, please indicate whether financial reporting obligations also extended to Casinos, and whether the Banking Supervision Department of the Central Bank of the Seychelles, acting as an FIU, is the designated authority to receive such reports. (...) (Extracts of the Licensing Act pertaining to the activities of Casinos are attached). 7 S/2005/107 In January 1998, Casinos and other gambling and betting services were included in the schedule as an activity required to notify the Central Bank under Section 5 (2) of the Anti – Money Laundering Act 1996, of any activity carried out or proposed to be carried out which constitutes or is likely to constitute an offence of money laundering.

If the situation so requires, the Commission may intervene in the operation of a casino. In addition, if an enforceable decision is not complied with in spite of a notice of default, the Commission may, automatically and at the casino’s expense, enforce the measures ordered and publicize the casino’s refusal to comply with the decision (art. 50, LMJ). The Casinos Act also provides for the imposition of administrative penalties. (...) In addition to administrative penalties, the Casinos Act provides for criminal penalties (arts. 55 and 56, LMJ).