Regulatory Alerts2010-06-30
Added
Casino or Card Club Risk-Based Compliance Indicators
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.