Procedures for using all available information to determine any transactions or patterns of transactions required to be reported as suspiciousįailing to comply with Title 31’s regulations can result in investigations and hefty fines.Procedures for using computers to aid in assuring compliance, if the casino has computerized systems.Procedures for using all available information to determine, when required, the name, address and Social Security Number (SSN) of a person, as well as to verify their identity.A compliance officer responsible for day-to-day compliance with Title 31 and the casino’s AML program.Independent testing for compliance, the scope and frequency of which correlated with the specific casino's money laundering and terrorist financing risks.Continuous training of casino employees, including in identifying unusual and/or suspicious transactions.Internal controls (policies and procedures designed to assure compliance with Title 31 and the Bank Secrecy Act).What does your casino’s anti-money laundering training program need in order to be Title 31-compliant? The company’s compliance program must include several elements, including at the very least:
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