This has to be good: Casino or Card Club Risk-Based Compliance

by YankeeJim | June 30, 2010 at 02:41 pm

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Casino or Card Club Risk-Based Compliance Indicators

I get a lot of information coming my way about diverse subjects. I particularly like the Financial Crimes Network information. Suffice it to say that the information is deep in detail and here is an example of the cream on top.

Government is big and expensive because our society is complex and there are so many aspects that require regulation. The most vulnerable parts for exploitation by global criminals are, you guessed it, the gaming industry. So, you and I have to fork over large sums of taxes to protect us against ourselves?

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“This document describes factors that a casino or card club may need to consider in applying a risk-based approach to the development and implementation of a Bank Secrecy Act (“BSA”) compliance program. The BSA requires casinos and card clubs to develop and implement compliance programs tailored to business activities and customer risk profiles (e.g., type of products and services offered, the locations served, and the nature of their customers). Please note that the business/customer risk factors described below will not apply equally to all casinos and card clubs, and even when these factors are present, there may be different risk outcomes for different casinos and card clubs. A casino or card club may not be required to address each of the factors described below; also a casino or card club should not construe the risk indicators below as exhaustive and the only ones required to be addressed.”

“Customer Risk Indicators

Although any type of customer activity is potentially vulnerable to money laundering or terrorist financing, certain customers may pose specific risks. In assessing customer risk, casinos and card clubs may need to consider other variables, such as services sought, products used, and geographical locations. For example, a casino or card club may need to consider the following:

• Particular aspects of operations (i.e., products, services, games, and accounts or account activities) that can be used by customers to facilitate money laundering and terrorist financing;

• Non-resident aliens and foreign nationals with deposit accounts who are citizens of countries or jurisdictions that are:

- Identified as non-cooperative by the Financial Action Task Force (FATF)3,

3 FATF is an inter-governmental body whose purpose

- Identified as Jurisdictions of Concern or Jurisdictions of Primary Concern in the U.S. Department of State’s annual International Narcotics Control Strategy Report (INCSR),4

- Designated as jurisdictions of primary money laundering concern or subject to special measures through regulations issued by FinCEN, pursuant to Section 311 of the USA PATRIOT Act,5 or

- Sanctioned by the Office of Foreign Assets Control (OFAC), including those with state sponsored terrorism. 6”