Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Independent Testing • Auditor (or firm) must have sufficient knowledge to audit Title 31
• Receive training, industry emails from FinCEN, IRS, etc.
Independent Testing • More than just a cursory review o MTLs signed, added correctly, etc. • SAR focus o Was money gamed o Was a player’s card inserted when 5 $1,000 tickets inserted into the TRM (kiosk) • Does amount gamed make sense based on our knowledge of the customer?
BlueBird, CPAs
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