Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Common Issues - IRS • Not using all available information for SAR reporting • Incorrect Legal name used for Tribal Casinos o If no legal corporation or partnership, legal name is Tribe’s name • Source of funds risk mitigation • Bank audits of Casinos
Independent Testing • 1021.210(b)(2)(ii)
“Internal and/or external independent testing for compliance. The scope and frequency of the testing shall be commensurate with the money laundering and terrorist financing risks posed by the products and services provided by the casino.”
BlueBird, CPAs
17
Made with FlippingBook Annual report