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One student spent $819,000 in cash for chips in 2015, the memo said.

The memo and other documents obtained by Postmedia suggest that some BCLC patrons are acting as “nominees” — meaning a fake buyer used to hide the true source of wealth in a potential money laundering transaction.

“These patrons do not always work alone,” the Aug. 2016 internal memo said. “It is not unusual for multiple patrons from different occupational categories to be involved in a single suspicious transaction.”

There is a similar concern related to bank draft deposits for VIPs who have been shifted by BCLC from cash buy-ins to the use of “patron gaming funds.”

“Use of nominees bringing in bank drafts that do not have the bank account customer/account holder’s name on it,” is a concern to BCLC’s patron gaming fund system, as is “patrons bringing in bank drafts from multiple banks,” documents state.

In the River Rock high-roller audit, there were just six patrons who claimed to be in the “Petroleum” industry. But these gamblers spent $6.1 million in cash in 2015. About 69 per cent of these transactions were suspicious. Auditors attributed this alarming statistic to an unidentified “individual in the group.”

The memo noted that as most of the high-risk gamblers are from China, much background information could not be verified, because gamblers presented English-language approximations of Chinese character names.

“The legitimacy of the 52 companies listed by the top 62 patrons were reviewed and testing was found to be inconclusive,” the memo said. “We were unable to conclusively determine whether the companies exist. Obtaining the characters of the companies given by high rollers would help … determine whether the positions given could support the level of play.”