2010-06-30
Added · Updated
This guidance describes factors that casinos and card clubs may consider when applying a risk-based approach to developing and implementing a Bank Secrecy Act compliance program. It outlines general business risk indicators, such as gross annual gaming revenue, physical layout, types of gambling offered, and location characteristics, as well as customer risk indicators including non-resident aliens from specific jurisdictions, high-value gambling by non-accountholders, and unusual spending patterns. The document states that these risk indicators are not exhaustive and may not apply equally to all entities, requiring casinos and card clubs to tailor their compliance programs to their specific business activities and customer risk profiles.
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FIN-2010-G002
Issued Date
Guidance Subject
Casino or Card Club Risk-Based Compliance Indicators
This document describes factors that a casino or card club may need to consider in applying a risk-based approach to the development and implementation of a Bank Secrecy Act ("BSA") compliance program. The BSA requires casinos and card clubs to develop and implement compliance programs tailored to business activities and customer risk profiles ( e.g. , type of products and services offered, the locations served, and the nature of their customers). Please note that the business/customer risk factors described below will not apply equally to all casinos and card clubs, and even when these factors are present, there may be different risk outcomes for different casinos and card clubs. A casino or card club may not be required to address each of the factors described below; also a casino or card club should not construe the risk indicators below as exhaustive and the only ones required to be addressed.
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Source: Financial Crimes Enforcement Network — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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