Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Source of Funds • Source of funds o How to implement (most common) • Top XX number of players (10, 15, 25, 30, etc.) • IRS looking at roughly 25 of your top players • CTR/SAR threshold o Conduct risk assessment to determine threshold
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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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BlueBird, CPAs
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