This afternoon at G2E, a panel discussion session was held with industry experts and FinCEN to discuss the practicalities of implementing Title 31 and comprehensive AML programs at Nevada's casinos.
For decades Nevada casinos operated under an anti-money laundering regulation of the state's Gaming Control Board known as Regulation 6A. As of July 2007, however, Regulation 6A was repealed and Title 31 was implemented in its place. Now under Federal regulation via the U.S. Treasury Department's Bank Secrecy Act, Nevada casino operators have had three months to evaluate the new system.
Nevada casino executive panel members discussed their own experiences during the recent July transition to Title 31, and suggested solutions to compliance questions posed by the audience participants.
This session, moderated by Thomas Peterman, Senior Vice President & General Counsel, MGM Mirage, leveraged input from these industry luminaries:
Peggy Jacobs - Executive Director & Casino Controller, MGM Grand Hotel & Casino
Barbara Rose - Manager, Audit Research & Special Projects, Harrah's Entertainment, Inc.
Len Senia - Senior Regulatory Program Specialist, FinCEN, U.S. Department of the Treasury
Panel members presented a number of key considerations from their Title 31 transition experiences:
- Maintaining a log of patrons refusing to provide their SSN
- Handling barred patrons since Title 31 does not have a provision for this
- State regulators requesting the logging of non W2-G jackpots, though Title 31 CTR-C reporting does not require it
- Handling "cash for cash" types of transactions
- Changes to the IRS audit process for casinos' AML program
- Components of a property's AML program (e.g. risk analysis, required documentation, staff training, testing, etc.)
- The creation and function of the SAR and AML Compliance committees
- The potential impact of Marketing / Player Development in the property's AML program
- The number of SAR-C filings are generally not in line with the risk level associatged with the industry
- Challenges in logging transactions and reporting on the NIL