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Anti-Money Laundering (AML) Basics
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AML
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.
KYC
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.
Suspicious Activity Report (SAR)
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.
Currency Transaction Report (CTR)
A report that casinos must file for any transactions involving currency exchanges over
FinCEN
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.
Money Laundering
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.
Player Rating System
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.
Enhanced Due Diligence (EDD)
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).
Title 31 Compliance
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.
Risk-Based Approach (RBA)
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.
Politically Exposed Persons (PEPs)
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.
Tipping Off
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.
Placement
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.
Layering
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.
Integration
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.
Beneficial Ownership
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.
Compliance Program
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.
Internal Controls
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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