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.