Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
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?
31
Independent Testing • SAR focus vs CTR focus
• Casino to prove why activity is not suspicious
• Missed filings? (CTR or SAR)
32
BlueBird, CPAs
16
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