April 2019 - Level III Training Material

Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Independent Testing • SAR focus vs CTR focus

• Casino to prove why activity is not suspicious

• Missed filings? (CTR or SAR)

From the Horse’s Mouth! • Below are the expectations of Raymond Dillion, Group Manager of the IRS Las Vegas, as discussed at IIA gaming conference. • SAR decision making process analyzed • Don’t just look at what was filed. Look for what isn’t being filed. • Are you doing transactional analysis • Are you leveraging ALL available data? Do you know all data fields such as bills-in

BlueBird, CPAs

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