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Anti-Money Laundering (AML) Basics

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AML

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Anti-Money Lauining; a set of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. Casinos must comply with AML laws to prevent financial crimes.

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KYC

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Know Your Customer; the process businesses use to verify the identity of their clients. Casinos use KYC to prevent fraud and money laundering by identifying suspicious players.

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Suspicious Activity Report (SAR)

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A document that casinos and other financial institutions must file with the Financial Crimes Enforcement Network (FinCEN) when they suspect a customer is involved in money laundering or fraud.

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Currency Transaction Report (CTR)

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A report that casinos must file for any transactions involving currency exchanges over 10,000inasingledaytoensurefinancialtransparencyandcombatmoneylaundering.10,000 in a single day to ensure financial transparency and combat money laundering.

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FinCEN

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Financial Crimes Enforcement Network; a bureau of the U.S. Department of the Treasury that collects and analyzes information about financial transactions to combat domestic and international money laundering, terrorist financing, and other financial crimes.

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Money Laundering

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The illegal process of making large amounts of money generated by criminal activity, such as drug trafficking or terrorist funding, appear to have come from a legitimate source.

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Player Rating System

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A system used by casinos to track the gaming activity of players for marketing, comping, and AML surveillance. It helps identify patterns that might indicate money laundering.

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Enhanced Due Diligence (EDD)

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Additional procedures taken to better establish customer risk in compliance with KYC regulations, particularly for clients perceived as higher risk for AML, such as politically exposed persons (PEPs).

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Title 31 Compliance

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Refers to the adherence of gaming establishments to the Bank Secrecy Act requirements for reporting and record-keeping of large cash transactions, which helps prevent AML activities.

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Risk-Based Approach (RBA)

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A method for managing money laundering and terrorist financing risks, which is adopted in the financial industry, including casinos, requiring customization of AML programs based on unique risks.

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Politically Exposed Persons (PEPs)

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Individuals who are or have been entrusted with a prominent public function and their family members and associates, who may present higher risks to financial institutions and casinos due to their positions.

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Tipping Off

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The act of notifying a customer that they are being investigated for suspicious activity, which is illegal under AML laws as it can compromise investigations.

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Placement

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The first stage of money laundering where illicit funds are introduced into the financial system, often through casinos by buying chips or using currency for gambling.

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Layering

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The second stage of money laundering involving the separation of illicit funds from their source via complex financial transactions to create confusion and sever links to the original crime.

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Integration

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The final stage of money laundering where the laundered money is returned to the criminal from what seems to be a legitimate source, often appearing as casino winnings.

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Beneficial Ownership

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Refers to individuals who have true control over a company or transaction, rather than those who may be nominal or apparent owners; essential for due diligence in AML.

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Compliance Program

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A set of internal policies, procedures, and controls that a casino implements to comply with AML laws and regulations and to prevent and detect money laundering activities.

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Internal Controls

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Processes that casinos establish to create checkpoints at various stages in financial transactions to detect and prevent money laundering and ensure AML compliance.

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