The Financial Crimes Enforcement Network (FinCEN) is under new leadership, and the gaming industry should continue to expect increased scrutiny by FinCEN and other regulatory bodies. With the continued evolution of compliance, it is important to remember the importance of Title 31/AML compliance. Casinos are required to have in place a comprehensive, written Anti-Money Laundering (AML) program that is “risk based” to ensure and monitor compliance with the Bank Secrecy Act (BSA) and several other AML regulations. This compliance program should have procedures for detecting and reporting suspicious transactions. At a minimum, each Title 31/AML program should include:
- Independent testing.
- A training program.
- A designated Bank Secrecy Act officer.
- Procedures for using all available information to monitor suspicious activity.
Wipfli offers consulting services in several different capacities related to Title 31/AML compliance. We can assist with the development of a comprehensive, risk-based program; perform independent testing; perform a risk assessment; perform training — live or web-based (JE University); or assist in remediation of IRS findings.
With Title 31/AML compliance, experience counts, so let Wipfli assist your casino with your Title 31/AML compliance.
Grant Eve, CPA, CFEGrant is a partner specializing in tribal and commercial gaming. He has several years of experience in working with tribal gaming organizations and commercial casinos throughout the United States. Grant is a nationally recognized leader in the gaming industry and has testified before the U.S. senate, authored numerous articles and been interviewed in several industry publications.