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Casinos have taken steps toward expanding their current compliance programs by implementing transaction monitoring systems. For the purposes of meeting customer identification program CIP and customer due diligence CDD requirements, casinos should also be collecting and documenting patron information. Jump to a Topic:. Regularly scheduled trainings will keep casino employees informed of key issues facing casinos, such as the avoidance of reporting by guests. Casinos generally employ multiple technology platforms to manage several aspects of the business, including but not limited to player reward accounts, gaming transaction tracking, cash activity aggregation and regulatory reporting. Changing the culture within an institution remains one of the most underestimated aspects of improving a compliance program. Together, these functions can provide a robust regulatory, compliance and risk management foundation to support long-term success. And while casino executives should assess how current solutions can be improved upon, it is equally important to equip casino employees with the knowledge and tools to be an effective first line of defense. Understand the Risks First May 8, Next Post. He has almost 15 years of experience in the application of data analytics technologies to business disputes, securities litigation, forensic investigations , anti-money laundering and contract compliance issues. Developers will attempt to tailor the rules and thresholds to align with the casino business model. Supreme Court decision on May 14, , permitting each individual U. Special Coverage. This effort is typically expensive and may result in either too few generated alerts or too many false positives. Without effective data quality and data governance programs, it is difficult to analyze transaction activity patterns and find important relationships. Implementing technology and procedural improvements can yield significant benefits through both cost savings and delivering strong financial crime fighting processes. However, if casino employees do not understand the importance of, and comply with, these updates, then the compliance program will not be effective. Friday, June 5, Home Risk. Summarizing patron activity across the casino, including historical transactions, requires a patchwork of information that can be difficult to collect and more difficult to analyze. Casinos are currently reviewing patron identification for confirming legal age to participate in gaming activities. These transaction monitoring improvements have led to an increased number of SARs filed by casinos annually. The Casino industry continues to learn and improve upon compliance obligations. In spite of these shortcomings, the implementation of these systems has been instrumental in identifying suspicious activity trends that would be more difficult to identify through a manual process, such as minimal gaming or structuring chip cash-out to avoid reporting requirements. Effectively training staff to identify, mitigate and document suspicious activity can help mitigate potential risk on the casino floor. Casinos should remain diligent by performing periodic reviews of their transaction monitoring solutions to determine effectiveness, and they should proactively tune the alert generation process to address changes in products and services, shifts in client profile and business model changes that may impact gaming volume. Therefore, it is imperative that assessments are performed regularly to ensure that data collection and storage procedures are being executed consistently. Follow Us.{/INSERTKEYS}{/PARAGRAPH} Considering ACH Payments? Casino compliance officers would be wise to consider focusing early on four areas: collecting patron information, implementing effective transaction monitoring controls, improving data quality and instilling a culture of compliance with casino employees. The creation of a single source of patron information, including know your customer KYC and CDD, plus the insight delivered by ongoing pattern matching using advanced technology, is a powerful framework for continually assessing patron risk. Therefore, FinCEN has called on casino executives and board members to lead the charge by regularly reviewing core business practices and guest offerings to determine whether they present heightened AML risks. {PARAGRAPH}{INSERTKEYS}Following the U. Privacy Policy. Furthermore, many transaction monitoring systems today are designed for banking customers. Recent reports by FinCEN detail instances of casino employees not upholding these due diligence requirements or adequately monitoring international wire transfers from its clients for suspicious activity. January 3, Related Posts. Sports wagering is expected to bring in a wave of new customers and revenue from various streams over the coming months.