7/13/21
ANTI MONEY LAUNDERING • Under 31 CFR 1010.210, each casino must develop and implement a written anti-money laundering (AML) program based on an analysis of the risks presented by the casino’s products and services. • An effective AML program is designed to prevent the casino from being used to facilitate money laundering and terrorist financing.
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Casino size Casino Location (including distance between casinos) Dollar volume
FACTORS TO CONSIDER WHEN FORMING AN AML PROGRAM/DETER MINING STAFFING
Types of games
Type/nature of customers Whether recordkeeping is done separately among casinos Existing compliance structure
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