Training Program
Requirements for a Comprehensive AML Compliance Program Presented by: Mindy Letourneau, Casino Essentials 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Learning Objectives
Today, we will learn what is required to adhere to Title 31 Federal Regulations requirements for a risk-based AML compliance program.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Learning Objectives • Define the four pillars of compliance required to mitigate government fines and penalties. • Discover how to develop or revise an organization’s required AML compliance program. • Identify ways to create or improve an organization's comprehensive internal training program.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FOUR PILLARS OF AN AML PROGRAM Presented by Casino Essentials 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Agencies: IRS IRS: Internal Revenue Service Largest of Treasury’s bureau Determines, assesses and collects internal revenue for United States Audits & enforces United States Federal Codes including Title 31 Announced in 2007 IRS will audit all Casinos over the next 5 years.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
5
Agencies: FinCEN
FinCEN’s mission is to enhance U.S. national security, deter and detect criminal activity, and safeguard financial systems from abuse by promoting transparency in the U.S. and international financial systems. • The Financial Crimes Enforcement Network (FinCEN) supports law enforcement investigative efforts and fosters interagency and global cooperation against domestic and international financial crimes. It also provides U.S. policy makers with strategic analyses of domestic and worldwide trends and patterns.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
6
“Four Pillars” At a minimum, your AML program must include the following four pillars: 1. System of Internal Controls
2. Independent Testing of BSA Compliance 3. Compliance Officer Designation
4. Training for Appropriate Personnel
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Title 31 Overview BSA/AML/Title 31 Compliance Program
Identify & Measure Risk: •Products •Services •Customers •Geographic Locations •Other Compliance Requirements
Develop Applicable: •Policies •Procedures •Systems •Controls Internal Controls
Risk Assessment
Risk-Based Compliance Program •Internal Controls •Audit / Independent Review •BSA Compliance Officer •Training
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
RESULT
“Four Pillars” 1. System of Internal Controls This includes policies, procedures and internal controls designed to ensure ongoing compliance. Internal Controls should provide for: • Effective risk assessment with updates • Develop policies and procedures
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 1. System of Internal Controls Internal Controls should provide for: • Implement policies and procedures;
• Filing required reports; • Creating and maintaining required records;
• Responding to law enforcement requests ,and; • Use all available resources (i.e., automated systems) 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 1. System of Internal Controls Ask yourself: Do the IC’s (internal controls) address the risks identified in our risk assessment? For example: Your casino cashes an $11,000 check for cash – have processes been implemented to review check cashing activity and ensure CTRs are filed?
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 1. System of Internal Controls Ask yourself: • Are the IC’s (internal controls) periodically reviewed and working as intended? • For example: Your casino has a policy that all transactions of $3,000 or greater must be logged on a multiple transaction log? Is the staff using the log? Is the log assisting in the reporting requirement? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 1. System of Internal Controls Ask yourself: • Is there a reporting process to ensure management is provided periodic updates on BSA compliance? • Do employees know what steps to take in the event of an unusual transaction? • If an employee identifies a weakness in the IC’s, is there a method for communicating it? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 2. Independent Testing of BSA Compliance The primary purpose of the independent review: • Determine the adequacy of your AML program, • Determine if the casino is operating in compliance with the BSA requirements
• Determine if the casino is operating in accordance with its own policies and procedures.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 2. Independent Testing of BSA Compliance • Your AML program must provide for an independent review of the program in order to assess effectiveness. • The review need not be a “formal audit” by a Certified Public Accountant (CPA).
• Consider what is at risk when choosing who will do your Independent Testing!
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 2. Independent Testing of BSA Compliance It should be “fair and unbiased appraisal” of the following: • Policies and Procedures • Internal Controls • Recordkeeping • Reporting functions • Training Program
Who does your independent testing? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 2. Independent Testing of BSA Compliance What does independent testing involve? • Review is based on risks • Tests the Risk Assessment for reasonableness • Determines the adequacies of risk mitigation strategies chosen by casino • Should include transactional testing to determine if policies, procedures, IC’s are working correctly • Documentation and follow up
Who does your independent testing? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 3. Compliance Officer Designation • You must designate a qualified individual to serve as the BSA compliance officer. • The CO is responsible for ensuring day-to-day BSA compliance and the following: • Casino properly files reports & maintains records;
• AML Program is updated to reflect Federal changes; and, • Appropriate training and education or applicable staff. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 3. Compliance Officer Designation What’s Critically Important? • Level of authority and responsibility within Casino • CO’s knowledge of the Regulation • CO’s knowledge of casino’s offerings, customers, geographic locations, etc. • CO’s oversight of Overall Program
• Do they have the expertise, authority and resources to satisfactorily complete the job? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars”
4. Training for Appropriate Personnel • Appropriate personnel are trained in all applicable aspects of the BSA and their own responsibilities under the AML program. • Training required in the detection of suspicious transactions to appropriate personnel.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 4. Training for Appropriate Personnel • Required for all personnel whose duties require BSA knowledge
• Required for new staff prior to working with patrons • Training should be “ongoing” and include any internal changes (policies, procedures, monitoring /automated systems)
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Developing a Risk-Based AML Program
The Four Pillars • Risk Assessment: Should be an ongoing process. • Management should understand their BSA/AML risk exposure and develop appropriate policies, procedures and processes to monitor and control BSA/AML risks. • For those with a higher BSA/AML risk profile, management should provide a robust program that specifically identifies, monitors and controls the increase in risk. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
RISK BASED PROGRAM Presented by Casino Essentials
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
General Business Risk Indicators
There are many risk indicators or factors that a casino or card club may need to consider when developing and implementing an effective BSA compliance program to combat money laundering and terrorist financing. Differ depending on the business activities Risk management principles and profile Other factors: FIN-2010-G002 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Customer Risk Indicators
Although any type of customer activity is potentially vulnerable to money laundering or terrorist financing, certain customers may pose specific risks. • Identify specific risk factors and analyze
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
INTERNAL TRAINING PROGRAM Presented by Casino Essentials
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
• Determine whether the following elements are adequately addressed in the training program and materials: • The importance the board of directors and senior management place on ongoing education, training, and compliance.
• Employee accountability for ensuring BSA compliance.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
• Determine whether the following elements are adequately addressed in the training program and materials: • Comprehensiveness of training, considering specific risks of products and services. • Training of personnel from all applicable positions • As part of this element, conducts adequate training for any agents who are responsible for conducting any BSArelated functions on behalf of the casino. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
Determine whether the following elements are adequately addressed in the training program and materials: • Frequency of training. • Documentation of attendance records and training materials • Coverage of policies, procedures, processes, and new rules and regulations. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
Determine whether the following elements are adequately addressed in the training program and materials: • Coverage of different forms of money laundering and terrorist financing as it relates to identification and examples of suspicious activity.
• Penalties for noncompliance with internal policies and regulatory requirements.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
• Consistent Message • Approved Materials
• New Hire training timeliness • Refresher training timeliness
• Assessments and Tests • Record Retention and Storage 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training FAQS
1. We prefer to test our employees and if they pass, they do not need to train. Is this sufficient?
2. Where does it state, specifically in the regulation, that we are required to train annually? 3. We do not want to test our employees. Is this required? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training FAQs
• My Casino will not allow me to attend spend money on my professional development. Is there anything specific in the regulation that requires me to have a certain level of expertise, experience or ongoing professional development? • Assigned staff possess the experience levels and are provided with comprehensive and ongoing training to maintain their expertise.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training FAQs
1. Does my C-level (CEO, COO, Executive VP) team need to train? 2. My C-level team will not attend my training classes. What should I do? 3. How do casinos train and track their AML training programs? 4. What should I retain in the event of an audit? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
Question 22: What type of compliance training program should be developed and what types of documentation should be maintained by a casino or card club to ensure that it has an adequate, accurate, and complete program? Answer 22: One of the more important elements of the anti-money laundering compliance program is the obligation to institute an effective and ongoing training program for all appropriate casino or card club personnel. Such a compliance training program should be commensurate with the risks posed by the products and financial services provided.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
Training should be provided to all personnel before conducting financial transactions on behalf of a casino at the cage (including casino credit and slot booth), on the floor (including table games, keno, poker, other floor games, and slot machines/video lottery terminals), as well as those responsible for complying with BSA currency transaction and suspicious transaction reporting, identification, recordkeeping, and other compliance program requirements. Also, a casino or card club is required to maintain, and to retain, a copy of the compliance program documentation. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
This documentation should include all casino records, documents, and manuals substantiating the training program as well as the training of appropriate personnel. The requirement is flexible and allows each compliance training program to depend on the characteristics of an individual casino. For example, a large casino having many table games, slot machines/video lottery terminals, and cage windows might need a more comprehensive training program than a small casino with no table games. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
A compliance procedures manual for employees should cover all applicable divisions or departments (e.g., table games, slot operations, keno, poker), other operational departments (e.g., cage operations, casino credit, slot booth), as well as other departmental functions (e.g., accounting, finance, information technology, marketing, surveillance). 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
Also, recordkeeping procedures should reflect the types of financial services provided. In addition, the training program should ensure that casino front-line employees, such as cage personnel (e.g., shift managers), cage cashiers, front window cashiers (i.e., general cashiers), pit personnel (e.g., pit bosses), floor persons (i.e., raters), dealers, and slot personnel (e.g., slot supervisors, slot attendants, slot cashiers, change persons) have appropriate training to detect the occurrence of unusual or suspicious casino transactions. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Title 31 Overview BSA/AML/Title 31 Compliance Program
Identify & Measure Risk: •Products •Services •Customers •Geographic Locations •Other Compliance Requirements
Develop Applicable: •Policies •Procedures •Systems •Controls Internal Controls
Risk Assessment
Risk-Based Compliance Program •Internal Controls •Audit / Independent Review •BSA Compliance Officer •Training RESULT 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Questions? Mindy Letourneau Managing Director Casino Essentials, LLC t: 877.811.3534 x102 c: 619.994.4402 cell f: 619.202.6627 fax [email protected] www.CasinoEssentials.com
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Learning Objectives
Today, we will learn what is required to adhere to Title 31 Federal Regulations requirements for a risk-based AML compliance program.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Learning Objectives • Define the four pillars of compliance required to mitigate government fines and penalties. • Discover how to develop or revise an organization’s required AML compliance program. • Identify ways to create or improve an organization's comprehensive internal training program.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FOUR PILLARS OF AN AML PROGRAM Presented by Casino Essentials 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Agencies: IRS IRS: Internal Revenue Service Largest of Treasury’s bureau Determines, assesses and collects internal revenue for United States Audits & enforces United States Federal Codes including Title 31 Announced in 2007 IRS will audit all Casinos over the next 5 years.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
5
Agencies: FinCEN
FinCEN’s mission is to enhance U.S. national security, deter and detect criminal activity, and safeguard financial systems from abuse by promoting transparency in the U.S. and international financial systems. • The Financial Crimes Enforcement Network (FinCEN) supports law enforcement investigative efforts and fosters interagency and global cooperation against domestic and international financial crimes. It also provides U.S. policy makers with strategic analyses of domestic and worldwide trends and patterns.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
6
“Four Pillars” At a minimum, your AML program must include the following four pillars: 1. System of Internal Controls
2. Independent Testing of BSA Compliance 3. Compliance Officer Designation
4. Training for Appropriate Personnel
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Title 31 Overview BSA/AML/Title 31 Compliance Program
Identify & Measure Risk: •Products •Services •Customers •Geographic Locations •Other Compliance Requirements
Develop Applicable: •Policies •Procedures •Systems •Controls Internal Controls
Risk Assessment
Risk-Based Compliance Program •Internal Controls •Audit / Independent Review •BSA Compliance Officer •Training
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
RESULT
“Four Pillars” 1. System of Internal Controls This includes policies, procedures and internal controls designed to ensure ongoing compliance. Internal Controls should provide for: • Effective risk assessment with updates • Develop policies and procedures
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 1. System of Internal Controls Internal Controls should provide for: • Implement policies and procedures;
• Filing required reports; • Creating and maintaining required records;
• Responding to law enforcement requests ,and; • Use all available resources (i.e., automated systems) 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 1. System of Internal Controls Ask yourself: Do the IC’s (internal controls) address the risks identified in our risk assessment? For example: Your casino cashes an $11,000 check for cash – have processes been implemented to review check cashing activity and ensure CTRs are filed?
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 1. System of Internal Controls Ask yourself: • Are the IC’s (internal controls) periodically reviewed and working as intended? • For example: Your casino has a policy that all transactions of $3,000 or greater must be logged on a multiple transaction log? Is the staff using the log? Is the log assisting in the reporting requirement? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 1. System of Internal Controls Ask yourself: • Is there a reporting process to ensure management is provided periodic updates on BSA compliance? • Do employees know what steps to take in the event of an unusual transaction? • If an employee identifies a weakness in the IC’s, is there a method for communicating it? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 2. Independent Testing of BSA Compliance The primary purpose of the independent review: • Determine the adequacy of your AML program, • Determine if the casino is operating in compliance with the BSA requirements
• Determine if the casino is operating in accordance with its own policies and procedures.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 2. Independent Testing of BSA Compliance • Your AML program must provide for an independent review of the program in order to assess effectiveness. • The review need not be a “formal audit” by a Certified Public Accountant (CPA).
• Consider what is at risk when choosing who will do your Independent Testing!
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 2. Independent Testing of BSA Compliance It should be “fair and unbiased appraisal” of the following: • Policies and Procedures • Internal Controls • Recordkeeping • Reporting functions • Training Program
Who does your independent testing? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 2. Independent Testing of BSA Compliance What does independent testing involve? • Review is based on risks • Tests the Risk Assessment for reasonableness • Determines the adequacies of risk mitigation strategies chosen by casino • Should include transactional testing to determine if policies, procedures, IC’s are working correctly • Documentation and follow up
Who does your independent testing? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 3. Compliance Officer Designation • You must designate a qualified individual to serve as the BSA compliance officer. • The CO is responsible for ensuring day-to-day BSA compliance and the following: • Casino properly files reports & maintains records;
• AML Program is updated to reflect Federal changes; and, • Appropriate training and education or applicable staff. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 3. Compliance Officer Designation What’s Critically Important? • Level of authority and responsibility within Casino • CO’s knowledge of the Regulation • CO’s knowledge of casino’s offerings, customers, geographic locations, etc. • CO’s oversight of Overall Program
• Do they have the expertise, authority and resources to satisfactorily complete the job? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars”
4. Training for Appropriate Personnel • Appropriate personnel are trained in all applicable aspects of the BSA and their own responsibilities under the AML program. • Training required in the detection of suspicious transactions to appropriate personnel.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
“Four Pillars” 4. Training for Appropriate Personnel • Required for all personnel whose duties require BSA knowledge
• Required for new staff prior to working with patrons • Training should be “ongoing” and include any internal changes (policies, procedures, monitoring /automated systems)
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Developing a Risk-Based AML Program
The Four Pillars • Risk Assessment: Should be an ongoing process. • Management should understand their BSA/AML risk exposure and develop appropriate policies, procedures and processes to monitor and control BSA/AML risks. • For those with a higher BSA/AML risk profile, management should provide a robust program that specifically identifies, monitors and controls the increase in risk. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
RISK BASED PROGRAM Presented by Casino Essentials
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
General Business Risk Indicators
There are many risk indicators or factors that a casino or card club may need to consider when developing and implementing an effective BSA compliance program to combat money laundering and terrorist financing. Differ depending on the business activities Risk management principles and profile Other factors: FIN-2010-G002 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Customer Risk Indicators
Although any type of customer activity is potentially vulnerable to money laundering or terrorist financing, certain customers may pose specific risks. • Identify specific risk factors and analyze
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
INTERNAL TRAINING PROGRAM Presented by Casino Essentials
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
• Determine whether the following elements are adequately addressed in the training program and materials: • The importance the board of directors and senior management place on ongoing education, training, and compliance.
• Employee accountability for ensuring BSA compliance.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
• Determine whether the following elements are adequately addressed in the training program and materials: • Comprehensiveness of training, considering specific risks of products and services. • Training of personnel from all applicable positions • As part of this element, conducts adequate training for any agents who are responsible for conducting any BSArelated functions on behalf of the casino. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
Determine whether the following elements are adequately addressed in the training program and materials: • Frequency of training. • Documentation of attendance records and training materials • Coverage of policies, procedures, processes, and new rules and regulations. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
Determine whether the following elements are adequately addressed in the training program and materials: • Coverage of different forms of money laundering and terrorist financing as it relates to identification and examples of suspicious activity.
• Penalties for noncompliance with internal policies and regulatory requirements.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training Program
• Consistent Message • Approved Materials
• New Hire training timeliness • Refresher training timeliness
• Assessments and Tests • Record Retention and Storage 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training FAQS
1. We prefer to test our employees and if they pass, they do not need to train. Is this sufficient?
2. Where does it state, specifically in the regulation, that we are required to train annually? 3. We do not want to test our employees. Is this required? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training FAQs
• My Casino will not allow me to attend spend money on my professional development. Is there anything specific in the regulation that requires me to have a certain level of expertise, experience or ongoing professional development? • Assigned staff possess the experience levels and are provided with comprehensive and ongoing training to maintain their expertise.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Training FAQs
1. Does my C-level (CEO, COO, Executive VP) team need to train? 2. My C-level team will not attend my training classes. What should I do? 3. How do casinos train and track their AML training programs? 4. What should I retain in the event of an audit? 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
Question 22: What type of compliance training program should be developed and what types of documentation should be maintained by a casino or card club to ensure that it has an adequate, accurate, and complete program? Answer 22: One of the more important elements of the anti-money laundering compliance program is the obligation to institute an effective and ongoing training program for all appropriate casino or card club personnel. Such a compliance training program should be commensurate with the risks posed by the products and financial services provided.
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
Training should be provided to all personnel before conducting financial transactions on behalf of a casino at the cage (including casino credit and slot booth), on the floor (including table games, keno, poker, other floor games, and slot machines/video lottery terminals), as well as those responsible for complying with BSA currency transaction and suspicious transaction reporting, identification, recordkeeping, and other compliance program requirements. Also, a casino or card club is required to maintain, and to retain, a copy of the compliance program documentation. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
This documentation should include all casino records, documents, and manuals substantiating the training program as well as the training of appropriate personnel. The requirement is flexible and allows each compliance training program to depend on the characteristics of an individual casino. For example, a large casino having many table games, slot machines/video lottery terminals, and cage windows might need a more comprehensive training program than a small casino with no table games. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
A compliance procedures manual for employees should cover all applicable divisions or departments (e.g., table games, slot operations, keno, poker), other operational departments (e.g., cage operations, casino credit, slot booth), as well as other departmental functions (e.g., accounting, finance, information technology, marketing, surveillance). 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
FinCEN FAQ FIN 2007-G005 (11/17/07)
Also, recordkeeping procedures should reflect the types of financial services provided. In addition, the training program should ensure that casino front-line employees, such as cage personnel (e.g., shift managers), cage cashiers, front window cashiers (i.e., general cashiers), pit personnel (e.g., pit bosses), floor persons (i.e., raters), dealers, and slot personnel (e.g., slot supervisors, slot attendants, slot cashiers, change persons) have appropriate training to detect the occurrence of unusual or suspicious casino transactions. 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Title 31 Overview BSA/AML/Title 31 Compliance Program
Identify & Measure Risk: •Products •Services •Customers •Geographic Locations •Other Compliance Requirements
Develop Applicable: •Policies •Procedures •Systems •Controls Internal Controls
Risk Assessment
Risk-Based Compliance Program •Internal Controls •Audit / Independent Review •BSA Compliance Officer •Training RESULT 2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
Questions? Mindy Letourneau Managing Director Casino Essentials, LLC t: 877.811.3534 x102 c: 619.994.4402 cell f: 619.202.6627 fax [email protected] www.CasinoEssentials.com
2013 Gaming Conference April 3 – 5, 2013 / The Mirage / Las Vegas, NV, USA
