We are considering establishing a banking relationship with a casino. They have several smaller locations in which they utilize an armored car service for pickup and delivery to the armored car virtual vault.I realize they are considered a NBFI for purposes of BSA. I am searching for any specific requirements and some best practices for ongoing due diligence activities before we dive in. Do any of you have experience with this and input we can consider? Many thanks!

I would start here.

https://www.ffiec.gov/BSA_aml_infobase/pages_manual/OLM_091.htm

Banking NBFI's can be a significant burden and require significant compliance costs to properly monitor them. I hope you built this into any pricing when discussing this relationship.

I appreciate the input and reference. We are early in the process collecting information. From what I've seen so far, they have a good BSA program and risk assessment documented w/ recent exam, Compliance Officer assigned, and the currency is handled by armored car service. We use an automated AML application currently which certainly would help with the increased monitoring required.

who is the casino owned and operated by?