Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Source of Funds • Legitimate play ≠ no suspicious activity
• Level of play does not match information obtained during customer review o Suspicious Activity Report should be prepared
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Source of Funds Example SAR Scenario 1
• A credit union manager wagers approximately $192,000 in gaming devices from January 2014 through March 2014.
• What do you think? Suspicious?
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BlueBird, CPAs
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