Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
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
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IRS Focus • 4 areas of focus o Source of funds o Risk assessment and compliance program linkage o Information Sharing • 314(a) and 314(b) o Chip Walking o Suspicious Activity Reporting
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BlueBird, CPAs
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