🤑 Institute for Certified Gaming Industry Professionals - ICGIP

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ACAMS Training: Webinars Managing AML Requirements for Casinos As legalized gambling has boomed, so have AML requirements for gaming.


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Casinos’ AML Compliance Obligations | ACAMS
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With casinos now viewed as financial institutions, this AML white paper looks at what actions they must take to comply with the Bank Secrecy Act.


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If you are a registered gaming worker in a casino, you must also have Anti Money​-Laundering (AML) Training & Certification. In AML training you will learn about.


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Learn More CELEXA™ Platform Compliance Through Cloud Training, Testing and Tracking. Learn More AML Certification.


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With casinos now viewed as financial institutions, this AML white paper looks at what actions they must take to comply with the Bank Secrecy Act.


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If you are a registered gaming worker in a casino, you must also have Anti Money​-Laundering (AML) Training & Certification. In AML training you will learn about.


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AML Professional Development Program for Casinos development programs offered by ICGIP is the Anti-Money Laundering training development program.


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With casinos now viewed as financial institutions, this AML white paper looks at what actions they must take to comply with the Bank Secrecy Act.


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casino aml training

In cases where we find repeated willful violations of clear legal obligations, the Department of Justice and AFMLS will step in to criminally pursue these bad actors— both the individuals and, where appropriate, the financial institutions themselves. And when they do, their actions serve as a dual threat: their criminal conduct itself, of course, can threaten the safety and security of law-abiding citizens; in addition their use of the financial and banking systems to hide their gains—or to fund additional criminal conduct—undermines the integrity of those systems. The vast majority of financial institutions—and compliance officers—that take these duties seriously are, as I have noted, vital to our efforts to detect, investigate, and prosecute the criminal actors who seek to exploit our financial system. For this reason, compliance officers like many of you here today are critical to protecting the reputations of your institutions by preventing where possible or detecting and reporting criminal activity by customers seeking to exploit your services. In stark contrast to the outward glamour of Las Vegas casinos, compliance can be tedious, painstaking, and thankless. However, FinCEN must also work in partnership with these same financial institutions. These are just some of the elements of a strong compliance program. This is especially important for transfers between a U. This may sound straightforward in principle, but we have seen that it is all too often not implemented in practice. However, under a risk-based approach to compliance, steps should be taken to identify those customers, by gaming activity or personal background, who pose the greatest risk to your business. Since joining FinCEN a little over two years ago, I have gained a deeper understanding of the relevant perspectives and equities that exist across diverse financial sectors. And, I am very happy to be a part of the discussion. That concludes my prepared remarks. Despite the elevated risks present in these salons, Caesars failed to apply appropriate AML scrutiny, thus allowing some of the riskiest financial transactions to go unreported. Of course, it may be difficult for a casino or card club to truly know all of its customers that pass through its gaming floors. While FinCEN has been very active on this front in the last two years, make no mistake, the DOJ will pursue criminal charges and penalties against any financial institution—including casinos and card clubs—that willfully violates the BSA. But it is one thing to have the requisite tools in place; it is another to deploy those tools most effectively. In our BSA oversight role, we, of course, focus on compliance in all our regulated industry sectors. Maybe we will ask you to leave the casino account open so we can monitor the activity. For example, if one branch identifies potentially suspicious activity related to a customer, compliance personnel at other branches should be alerted to this activity. Nevertheless, because you do offer those financial services to your customers, you have taken on a great responsibility in the fight against illicit finance. The high level of attendance at this conference and the questions you have raised tells me that the casino industry continues to show a strong interest in developing a deeper understanding about these issues. Despite its importance, compliance often takes a back seat to other financial considerations. That view can be especially true in the gaming industry where financial services—and their attendant compliance costs—may be considered secondary to or even inconsistent with the primary mission of customer entertainment. It is important to remember that anti-money laundering and BSA compliance is not an end itself but is a means to an end: preventing criminal actors from using the U. I want to emphasize something here. Maybe we will seek a restraining order or a seizure warrant from a judge to give us time to gather more evidence. Thank you. Put differently, we look at whether an institution meaningfully stressed compliance or, when faced with a conflict between compliance and profits, chose profits. For example, when an institution unilaterally terminates a relationship with a suspicious customer, that termination might prompt the criminal to move and hide his illicit funds elsewhere. I would like to thank Mindy for the very kind introduction, as well as Jim Dowling, who invited me to speak today. You all—as industry leaders and compliance officers—play a significant role in the fight against illicit finance. The BSA provides FinCEN with broad supervisory and enforcement authority, allowing FinCEN to impose civil penalties not only against domestic financial institutions, but also against partners, directors, officers, and employees of such entities who themselves participate in misconduct. Some of the threats we are focusing on at FinCEN include Mexican drug trafficking organizations, transnational criminal organizations, frauds against U. In fact, the BSA was created to protect the integrity of the U. It is no secret that criminal actors seek to use the tools of our financial and banking systems to serve their illicit purposes: For an illegal enterprise to succeed, criminals must be able to hide, move, and get access to their criminal proceeds. These types of arrangements create an enticing method for criminals to move illicit funds to or through casinos or card clubs and their use should raise a red flag for compliance officers: You need to know the beneficial owners of those funds. They are necessary for the establishment and maintenance of an effective AML program, but they may not be sufficient given the specific risks confronting a particular institution. I am grateful for the opportunity to speak with you today, and am confident that this forum will prompt meaningful discussion regarding these important issues. Simply because funds are moved between affiliated casino accounts does not excuse the U. Then, if in your work you identify significant suspicious activity, you have a name and a phone number that you can call in law enforcement in addition to filing a SAR. Good morning. FinCEN is in a novel position as a regulator. In addition, we provide legal and policy assistance regarding anti-money laundering and asset forfeiture to federal, state, and local prosecutors and law enforcement, and also to foreign governments. And, I can assure you that we are continuing our work while we await the announcement of a new director. I would also like to thank Casino Essentials for hosting this Title 31 conference and inviting me to speak today. And we appreciate that, despite these challenges, you and your colleagues are committed to helping protect the integrity of your institutions and assisting law enforcement. By partnering with regulators and law enforcement, your institutions will be better positioned to detect and address illicit activity. Let me next provide a brief overview of FinCEN, for those of you who might not be as familiar with our role. Hawaiian Gardens routinely collected customer information through its player club card accounts. It is not an exaggeration to say that compliance is fundamental to protecting the security of our financial institutions and is essential to the integrity of our entire financial system. Caesars made the effort to identify and entice these customers to travel across the world to come gamble at their institution, but, when it came time to compliance with its legal BSA requirements, Caesars looked in the other direction. As compliance officers, you no doubt recognize your duty to ensure compliance by your institutions and prevent regulatory violations. This requires institutions to play a more proactive role that goes beyond simply filing SARs and cooperating with grand jury subpoenas. We expect you, as members of the financial community, to take compliance risk at least as seriously as you take other business-related risks. This may mean that a casino should be using its business side to assist the compliance side of the house. Thus both law enforcement and industry have a shared interest in ensuring effective BSA compliance. With approximately employees, we are relatively small considering our broad responsibilities. Casinos and card clubs should also make an effort to identify the beneficial owners of funds when it is apparent that transactions are being conducted by or through a third party. We also have the authority to obtain injunctions against institutions, as well as individuals, that we believe are involved in violations of the BSA. I want to also thank every one of you who are on the front lines of BSA compliance. Public-private partnerships are increasingly important for FinCEN to succeed in its mission, so I hope to impart the value of proactive engagement with the casino industry to combat illicit financial activity.{/INSERTKEYS}{/PARAGRAPH} With that in mind I would like to discuss what steps in particular the gaming industry should be taking to detect and deter illicit financial activity. By consulting with law enforcement upon discovery of suspicious activity, an institution may be able to avoid taking actions that unintentionally harm a criminal investigation or benefit the criminal. All of us here today share the goal of ensuring a financial system free from illicit proceeds and criminal abuse. We at the Department of Justice understand this reality. It bears noting outset that in my experience—when it comes to BSA compliance—most financial institutions are committed to fulfilling their obligations under the BSA and to ensuring that they avoid doing business with criminal actors. Too often, BSA compliance is regarded as a mere box-checking exercise, with more emphasis on process than results. This is why it is critical for the gaming industry to use all available information to identify its customers for BSA purposes. The reporting requirements the BSA imposes on financial institutions—including casinos—provide an invaluable source of information for law enforcement in our efforts to deter, detect, and prosecute criminal actors. Events like this serve a vital role in promoting constructive and open dialogue between industry, regulators, and law enforcement. As you are aware, FinCEN has had some recent changes in its senior management with the departure my predecessor, Stephanie Brooker, in April of this year, followed by our director, Jennifer Shasky Calvery, at the end of May. I am honored to be here talking with you about the importance of compliance with anti-money laundering AML requirements under title 31 of the Bank Secrecy Act. As a result, I strongly encourage each of you to take the opportunity— both today and once you return to your respective offices—to reflect on whether your institutions have effective AML programs and other compliance policies and practices to prevent or mitigate financial crime. I will also discuss some specific measures that the gaming industry can take to ensure that casinos and card clubs do not become conduits for criminals seeking to launder their illicit funds. These are all indicators that will help a casino or card club in truly knowing its customers and ensuring proper BSA compliance. A casino or card club may need to look at other factors, such as whether the customer is from a high-risk jurisdiction with poor AML controls, or is a politically exposed person from a country with significant public corruption. It must vigorously enforce the rules that financial institutions such as casinos and card clubs are required to follow to guard against money laundering, terrorist finance, and other financial crime. These are serious threats to the United States, our people, our businesses, and our communities. You represent an industry that is primarily focused on providing entertainment to its customer base, with financial services being a complementary element of your business model. The Department is keenly aware of the unique compliance challenges faced by casinos and card clubs. I can also assure you, that for at least the Enforcement Division, we will continue to follow the same trajectory with respect to our priorities and practices. Casinos and card clubs play a critical role in keeping our financial system safe from potential money laundering and terrorist finance. As I noted at the outset, financial institutions, including casinos and card clubs, are vital to our law enforcement efforts. We do consider potential individual liability. Our mission is to safeguard the financial system from illicit use and combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities. Despite having this significant trove of information regarding its customers, Hawaiian Gardens failed to utilize that information for suspicious activity reporting purposes. That kind of dialogue truly benefits all of us. Let me pause here to emphasize this point. Along those same lines, U. The requirement for casinos and other financial institutions to have effective anti-money laundering programs has been on the statute books only since , when Congress passed the Patriot Act, which included amendments that required casinos and other institutions to implement effective AML programs. For example, do the compliance officers have the ability to access and use information contained in business resources like customer club account cards or markers to assist in identifying a customer? Therefore, we urge you, as leaders of the gaming industry, to take prudent steps to know who you customers are, even and perhaps especially those who may be the beneficial owners of legal entities. It is for these reasons—the need to detect and deter criminal conduct AND to preserve the integrity of the financial systems they seek to exploit—that there are serious consequences for financial institutions that fail to satisfy their BSA obligations. {PARAGRAPH}{INSERTKEYS}Thank you, for the kind introduction. We do this, first and foremost, by prosecuting and coordinating complex, multi-district and even international money laundering and asset forfeiture investigations and cases. But, if you reach out to law enforcement proactively, there are a number of steps we might wish to take depending on the nature of what you have identified. Take advantage of the opportunity at this conference to get to know some of the law enforcement representatives who work on these issues. Furthermore, Caesars marketed these salons through branch offices in the U.