ITG FAQ #6 Answer-Are there any items that must be included in the casino’s anti-money laundering (AML) program?

Yes. There are several things that must be included in the program:

  • Internal controls (policies and procedures designed to assure compliance with the Bank Secrecy Act (BSA));
  • Training of the casino employees;
  • Independent testing for compliance ;
  • A compliance officer, who is responsible for day-to-day compliance with the BSA and the casino’s AML program;
  • Procedures for using all available information to determine, when required, the name, address and Social Security Number (SSN), and to verify the identity of, a person;
  • Procedures for using all available information to determine any transactions or patterns of transactions required to be reported as suspicious; and
  • Procedures for using computers to aid in assuring compliance, if the casino has computerized systems.

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