Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Source of Funds • Obtaining information without invading privacy o No longer gaming at Casino • Per FinCEN guidance, not an excuse • According to IRS “Begging for a penalty” o No guidance from FinCEN • AGA best practices 2014 and 2015 (handout) • Host vs Non-Host Casino’s o More difficult to obtain without hosts • Should use Google, Spokeo, Facebook, etc.
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Source of Funds • KYC Program should be established o Include: • How information is obtained • How it is verified • How it is retained • How it is secured (who has access) • How often it will be updated • At least annually
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BlueBird, CPAs
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