Stakeholder BSA Training A Casino Industry Primer

In 1985, the United States Department of Treasury amended 31 CFR Part 103 to include gambling casinos within the scope of financial institutions required to report and maintain records of certain transactions in currency. The regulations for the Bank Secrecy Act of 1970 and the U.S. Patriot Act of 2001, as they relate to casinos, have been amended several times and the most recent rule became effective on March 25, 2003.


The Financial Crimes Enforcement Network (FinCEN) is a bureau of the United States Department of the Treasury that collects and analyzes information about financial transactions in order to combat domestic and international money laundering, terrorist financing, and other financial crimes.

Money laundering is the process of creating the appearance that large amounts of money obtained from serious crimes, such as drug trafficking or terrorist activity, originated from a legitimate source.

Best practices identify five pillars to an effective BSA/AML program:
Designation of a AML Compliance Officer.

It may be good to establish a AML compliance committee, but make sure the committee is independent of the operations revenue interests. Ensure the operations revenue interests does not interfere with the AML decision process.

The duties of the Compliance Officer will include, but are not limited to making sure that; Policies and procedures are followed, Proper compliance training and education are provided, Reports are properly filed, Proper recordkeeping as mandated by local regulations and company policy, periodic reviews are conducted to verify the effectiveness of the Compliance Program, Ensuring both company requirements and regulations are followed, Maintaining compliance with licensing laws, Updating the Compliance Program as necessary due to changes in laws or regulations

Internal Policies, Procedures, and Related Controls,

A solid AML program will: Identify reportable transactions at a point where all of the information necessary to properly complete the required currency transaction reporting forms and suspicious activity reporting forms can be obtained. Ensure all required reports are completed accurately and properly filed. Provide for adequate training and supervision of employees who accept currency transactions and who complete report SAR’s. Establish dual controls and provide for separation of duties.

Training Program.

A training program provides for the training of all newly hired, reassigned and experienced casino, casino marketing and accounting personnel responsible for handling currency transactions and their supervisors and managers and completing and filing currency transaction reports and suspicious activity reports.

Independent Review for Compliance.

The Internal Audit Department conducts regularly scheduled compliance audits as part of its annual Audit Plan. Additionally, the Internal Audit Department conducts compliance audits as requested by Compliance Committee.

The results of each audit will be presented to the Compliance Committee in writing. The audit reports will include the scope, objectives, and findings of the audit and, if necessary, a response setting forth specifically any remedial action to be taken considering the findings of the audit report.

Establish Know Your Customer procedures

Know your customer (KYC) is the process of a business identifying and verifying the identity of its clients. The term is also used to refer to the bank regulation which governs these activities. Know your customer processes are also employed by companies of all sizes for ensuring their proposed agents, consultants, or distributors are anti-bribery compliant. Casinos, banks, insurers and export creditors are increasingly demanding that customers provide detailed anti-corruption due diligence information,


Gaming operations are accustomed to complying with regulations as they are defined by regulators, but OFAC highly encourages a risk-based approach to compliance, which has left many casinos asking what exactly is required of them. While OFAC does not mandate that casinos test every cash transaction and identify every patron, it does require casinos to examine their transactions, as well as the risk that a patron might be on the SDN List, and then put procedures in place to mitigate that risk.

As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked and U.S. persons are generally prohibited from dealing with them.

To ensure your stakeholders are aware of the risks of non-compliance, it is imperative to express the foundation of a formidable Band Secrecy Act compliance program. In addition, the legal, reputational, and operational consequence can be critical to a business.

William Owen Logan

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