Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Independent Testing • 1021.210(b)(2)(ii)
“Internal and/or external independent testing for compliance. The scope and frequency of the testing shall be commensurate with the money laundering and terrorist financing risks posed by the products and services provided by the casino.”
29
Independent Testing • Auditor (or firm) must have sufficient knowledge to audit Title 31
• Receive training, industry emails from FinCEN, IRS, etc.
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BlueBird, CPAs
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