AML/BSA - introductory guide to compliance for gaming industry compliance personnel. How to comply with federal and state law by building a rigorous compliance system.

1. AML/BSA
FOR THE GAMING INDUSTRY (CASINO AND INTERNET GAMBLING)

2. Regulatory and Supervisor Agencies:
 Financial Crimes Enforcement Network (FinCEN)
 U.S. Department of Treasury
 Internal Revenue Service (IRS)
 American Gaming Association
 State Gambling & Lottery Commissions
 Securities & Exchange Commission
 North American Gaming Regulators Association

3. TERMINOLOGY:
 AML – anti-money laundering
 BSA – Bank Secrecy Act (31 U.S.C. §§5311, et seq.)
 Cage – secured area adjacent to the gambling floor of a casino where casino cashiers conduct marker/credit, front-money and other gambling-
related transactions
 Chip walk – when patron leaves casino floor with significant amount of chips in their possession without offsetting chip redemptions or chip buy-ins
at another table and no known disposition of chips.
 Credit – issuance of chips up to the amount of the marker
 CTRs – currency transaction reports
 Front Money – cash, wired funds, or negotiable instruments deposited with casino by patron for gambling “safekeeping accounts”
 Marker – negotiable instrument (counter-check) executed by patron made payable to casino that authorizes the casino to withdraw the amount of
the marker from the patron’s bank account
 MIL/NIL - Monetary/Negotiable Instrument Log evidencing the transactions of monetary instruments between the casino and patron with value
above $3,000
 Multiple Transaction Log – record of cash-in and cash-out transactions at or above the pre-determined amount which also records identifying
information about the patron in order to determine when a person is approaching or exceeded a reportable threshold
 PEPs or SPFs - politically exposed persons or senior political figures are individuals who have been entrusted with a prominent public function (or
individuals related to those PEPs).
 SARs – suspicious activity reports
 TITO – ticket in/ticket out – a system for slot machine play through the use of a barcoded paper ticket

4. BSA/AML requirements for Gambling Industry
Businesses:
Requires casinos to design and implement risk-based AML programs that includes a
system of internal controls, policies & procedures that at a minimum identifies:
1. Patrons (by name, address, SSN, other information and verification of person),
2. When SARs are to be filed,
3. When and what records must be made and retained,
4. Internal and or external independent testing of compliance,
5. Training for personnel,
6. Designated AML/BSA officer, and
7. Data and process of integrating and or sharing that data within the casino’s entire
enterprise organization.

5. Risk Assessment
 Enterprise specific risks including:
 Entry and exit points of casino for funds
 Identification of casino departments or personnel best positioned to monitor
and detect the transportation of the funds
 Identification of the characteristics of transactions that most likely involve illicit
funds or patrons that are most likely to engage in suspicious activities.
 State specific regulatory requirements
 Gaming products, services and venue (type of casinos) and
jurisdiction/location

6. Effective Compliance System:
 BSA/AML Compliance Officer
 Employee Training (game operations, marketing, cage, surveillance, property, audit, senior
management)
 Policies and procedures relating to specific high risk areas or transactions:
 TITO redemptions
 Barring cash for cash exchanges
 Declining cash for purchase of casino check or wire
 Issuing checks or wires for patron for winnings
 Approval procedures for checks and wires to patron’s business or other account
 Suspension of patron’s loyalty club account or barring patrons if activity involves CTR or SARs
issues
 International venues compliance with laws, recordkeeping and reporting
 Marketing executives traveling outside US trained on international laws
 Eliminating cash play at poker tables
 Customer Due Diligence (initial and ongoing monitoring)
 Transaction Monitoring

7. Suspicious Activities:
 Gaming Floor Activity
 Race and Sports Book Activity
 Cage-Focused Activity
 Information from the back of the house (LEOs, news/media, FTC or other
regulator reported actions against patron’s or business’, etc.)
SARs should be filed as appropriate occurring to policies and procedures established by
the enterprise and in compliance with laws.
Review at least annually SARs previously filed to analyze patterns.
Maintain the confidentiality and information related to the SARs