As we all know, the casino and gaming industry is one of the most regulated industries in the country. Therefore, operators must ensure state regulations are met along with those outlined on the Federal level. Of these, Title 31 of the Bank Secrecy Act includes a few considerations operators must meet about anti-money laundering (AML) regulations.
At a minimum, Title 31 requires every casino's AML program to provide for all of the following:
- Internal controls (policies and procedures designed to assure compliance with Title 31 and the Bank Secrecy Act)
- Continuous training of casino employees, including in identifying unusual or suspicious transactions
- Independent testing for compliance, the scope and frequency of which correlated with the specific casino's money laundering and terrorist financing risks
- A compliance officer responsible for day-to-day compliance with Title 31 and the casino's AML program
- Procedures for using all available information to determine, when required, the name, address, and Social Security Number (SSN) of a person, as well as to verify their identity
- Procedures for using computers to aid in assuring compliance if the casino has computerized systems
- Procedures for using all available information to determine any transactions or patterns of transactions required reported as suspicious
Pavilion Payments' VIP Shield is designed to help operators adhere to these standards. VIP Shield provides casinos with a new level of compliance assistance by automating Anti-Money Laundering and IRS reporting processes, including Multiple Transaction Log (MTL), Negotiable Instrument Log (NIL), Monetary Instrument Log (MIL), chip log transactions and Suspicious Activity Reporting (SAR). In addition, the configurable, web-based solution provides custom reporting to isolate risk potential while automating 90% of MTL transactions, empowering operators to focus on their patrons.