πŸ’ Increasing Title 31 enforcement means casinos need to know their customers - CDC Gaming Reports

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The most common findings in those Title 31 exams were that casinos were failing to know their customer properly. Ongoing AML training; and.


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Will casinos (and other non-bank financial institutions) eventually need to be compliant with the β€œfifth pillar” of customer due diligence and.


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Insights into the intent of Title 31 and information on the reporting and recordkeeping requirements for casinos. necessary outreach and/or training as well as answer any questions that may arise with respect to this matter.


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A casino shall be deemed to satisfy the requirements of 31 U.S.C. (h)(1) if it (iii) Training of casino personnel, including training in the identification of.


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Internal controls policies and procedures to ensure Title 31 compliance; Casino employee training; Independent compliance testing; A.


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Title 31 Program, Training, and Compliance

She pointed out that the plan needs to be written and up-to-date and recommended that casinos that have not recently reviewed their plan do so and update as needed.

With the increase in Title 31 enforcement action, and considering the penalties for infractions, casinos need to have a plan in place to get relevant information about their customers, according to Know Your Customer: Title 31 Compliancea panel discussion held Wednesday morning at the NIGA Tribal Gaming Conference.

Several methods of authenticating government-issued IDs have been available for a while, she said, but the capability is now available on mobile devices.

The third member of the panel, Jamul Tribal Gaming Commission Executive Director Joe Osterloh, said that there had been increasing enforcement of Title 31 in card rooms in California, title 31 training for casinos he expects enforcement to become more of an issue for casinos.

This can be combined with live in-person identification using facial recognition to confirm identity, and these programs have become very accurate, she said. Osterloh related a recent case in which he got a message from the casino floor that there was a player pulling hundred title 31 training for casinos bills out of a backpack to gamble with.

There is an expectation that casinos use all available information to meet their Title 31 obligations, Magnusen said, so compliance officers need to have access to player information.

This makes it necessary for casinos to know their clients, so they need to create a program to achieve this, and casino employees need to be trained to understand their responsibilities.

The have real table top slot machines for sale pity must include customer identification procedures, including name, permanent address, social security number and ID verification.

Participation in this program, she said, has the advantage of providing the casino with a safe harbor.

Magnusen began the presentation with a brief overview of Title The Bank Secrecy Act was passed in mainly to prevent money laundering and tax evasion and was expanded to other industries, including casinos, in as a part of the Patriot Act with the added purpose of preventing terrorist financing. Julie Hakman, President and CEO of AmericanChecked, cited the technological advances that are making it easier for casinos to gather information about their customers. Sophisticated new technology also continues to make it easier to authenticate and confirm individual identities, another vital area of information gathering that casinos need to concern themselves with. One readily available resource that some compliance people tend overlook, she said, are the lists of excluded people maintained by state gaming control boards, including the Nevada Gaming Control Board. Casinos must also keep track of all reportable transactions and have a policy on situations in which gamblers may be anonymous. Magnusen pointed out that casinos need to be sure that the information they collect is very well secured. Hakman went on to say that the most common questions she gets from casinos usually deal with criminal background checks and noted that there are a wide range of tools available for these, including databases at the county, national and international levels. Transactions with no apparent lawful activity must be reported, she said. He was able to research the player and found out it was a recent lottery winner.