Q: How does the Gramm-Leach Bliley Act (GLBA) impact casinos in customer due diligence/know your customer? Regarding information shared across properties under a corporate umbrella, could we be in violation of patron privacy?

A: GLBA obligations attach in connection with the extension of credit and generally require financial institutions (including casinos that grant credit) to provide customers information regarding their information-sharing practices. GLBA is intended largely to protect customers' personally identifiable information and other customer personal information such as date of birth, address and SSN. What we are talking about with know your customer or enhanced customer due diligence, while it certainly includes verifying the identity of the customer, is trying to find information such as source of wealth/income, civil/criminal history, tax liens, bankruptcies, negative news reports, etc. A lot of that information will be found in the public domain. Having said that, every casino should have in place procedures to protect the personally identifiable information of customers, including those you’ve conducted a know your customer profile on.