7/13/21
FEATURES OF AN AML PROGRAM
• 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 • Internal controls designed to assure compliance with the Bank Secrecy Act
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• Helpful Internal Controls include: • Procedures for using all available information to
determine, when required, the name, address and Social Security Number, 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 • Procedures for using computers to aid in assuring compliance, if the casino has computerized systems
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