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Casinos Compliance with BSA/AML legislation and the MLSA
Question: With greater risks of money laundering, how can casinos ensure proper compliance with BSA/AML legislation and the MLSA?
Answer: In 1985, the BSA’s regulations were amended to include casinos under the definition of a financial institution. The Money Laundering Suppression Act of 1994 (MLSA) expanded this definition even further, to include both state-chartered and tribal gaming establishments.
Currently, 48 states permit some form of legalized gaming and this trend is quickly growing. Casino gaming accounts for more than 80% of the amounts wagered in gaming activities nationwide, which dramatically increases the risk of money laundering.
- Implement internal controls to assure ongoing BSA/AML Compliance.
- Perform independent testing of BSA/AML Compliance.
- Be sure to obtain and verify additional information about customers’ identities, particularly when they are opening an account or establishing a line of credit.
- Designate an individual or individuals responsible for coordinating and monitoring BSA/AML compliance.
- Make procedures and policies (e.g., filing a CTR for all transactions totaling more than $10,000) known to all employees.
- Ensure that all information in your BSA/AML Compliance program is accurate and all problems are corrected as soon as possible.
- Train employees to recognize possible red flags of money laundering, such as cash-for-cash exchanges involving small denomination bills for larger denomination bills in excess of $2,500.
- Provide job-specific training to all employees about your BSA/AML Compliance program, the law’s requirements and their individual responsibilities.
- Provide a method for employees to ask questions and get answers about BSA/AML Compliance.
- Be able to track, document and report upon your BSA/AML Compliance efforts, including training records.
The Edcomm Group
The Edcomm Group is a 19-year old multimedia training company specializing in the banking industry. The Edcomm Group offers programs such as Compliance, Teller, BSA, AML, EEO, Sexual Harassment, Elder Financial Abuse, Bank Risk, Credit Risk Management, Fraud Prevention, Security, Ethics, OSHA, Lending, Sales & Service, System Simulations, Retail Systems, System Conversions, Leadership & Operations Management. To learn more, please contact Dr. Linda Eagle, President of The Edcomm Group, at 888-433-2666 or linda.eagle@edcomm.com, and visit us on the web at www.bankersacademy.com.
First published on BankersOnline.com 2/04/08
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