AML Compliance in the Gaming Industry: What You Should Know in 2017 and Beyond
With the rise of gaming industry comes not only a wealth of opportunities for players and operators, but also the increasing possibility of criminal exploitation. As a result, various local, national and international regulations governing its operation are being made and developed, thus, creating a more complex environment for the whole industry. Businesses’ Anti-Money Laundering (AML) programs are being subjected to greater scrutiny despite the companies' efforts in combating money laundering. Aside from that, compliance officers may face personal liability for AML violations along with the company.
With the heightened regulatory focus and law enforcement efforts towards the enhancements of AML programs, it is important that gaming operators re-examine and update their AML compliance programs. Compliance officers must take necessary actions to avoid the risk of running afoul of the various AML law and regulations.
In this LIVE Webcast, a panel of key thought leaders organized by The Knowledge Group will provide an overview of the latest AML compliance trends and regulatory developments in the gaming industry. They will help the audience understand the critical issues that may affect their compliance practice and provide guidance on properly fulfilling their compliance obligations.
Key topics include:
- Financial Action Task Force (FATF) Guidance
- Customer Due Diligence (CDD) Requirements
- Bank Secrecy Act (BSA) Requirements
- Potential AML Risks for Gaming Operators
- Latest Regulatory Developments
- Recent Case Law and Law Enforcement Updates
- Effective AML Compliance Programs
- Creating a Culture of Compliance
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- Enforcement Actions Speak Louder Than Words:
- what administrative functions have been examined the most when anti-money laundering compliance has been questioned?
- how much control do gaming interests have over designing those functions so as to minimize perceived lapses?
- what guidance is available from governmental and non-governmental sources about what constitutes an effective AML compliance program?
- Are The Stars Aligning For A Casino-Oriented Geographical Targeting Order:
- what five factors always have preceded issuance of these unique AML enforcement tools for other industries?
- how many of those factors are present in the gaming industry?
- what preventative measures can be taken to minimize the likelihood of a casino-oriented GTO?
- Regulatory Framework
- Financial Crimes Enforcement Network (“FinCEN”) – Civil Enforcement
- Department of Justice (“DOJ”) – Criminal Enforcement
- Internal Revenue Service (“IRS”) – Civil and Criminal Enforcement (Performs Bank Secrecy Act (“BSA”) reviews at casinos)
- State Gaming Authorities – Civil and Criminal Enforcement
- Recent Enforcement Actions
- Cantor Gaming: On October 3, 2016, FinCEN assessed a $12 million civil penalty
- Hawaiian Gardens: On July 15, 2016, FinCEN assessed a $2.8 million civil penalty. On October 17, 2016, the California Gaming Commission filed an Accusation to revoke the Casino’s license.
- Sparks Nugget: On April 5, 2016, FinCEN assessed a $1 million civil penalty
- Oak Card Club: On December 17, 2015. FinCEN assessed a $650,000 civil penalty
- Ceasars Palace: On September 8, 2015, FinCEN assessed a $8 million civil penalty. Nevada Gaming Control Board fined Caesars Entertainment $1.5 million in 2015.
- Tinian Dynasty Hotel and Casino: On June 3, 2015, FinCEN assessed a $75 million civil penalty
- Trump Taj Mahal Casino Resort: On March 6, 2015, FinCEN assessed a $10 million civil penalty
- Regulatory Expectations
- A system of internal controls to assure ongoing compliance;
- Independent testing of the Casino’s AML compliance program;
- Training of personnel;
- Designation of an individual or individuals responsible for assuring day-to-day compliance;
- Procedures for using all available information to determine and verify name, address, social security or taxpayer identification number, and other identifying information for a person, to the extent determining and verifying the information is otherwise required under the BSA;
- Procedures for using all available information to determine the occurrence of any transactions or patterns of transactions required to be reported as suspicious;
- Procedures for using all available information to determine whether any records must be made and maintained pursuant to the BSA; and
- Automated data processing systems
- Trends and Hot Buttons
- Increasing penalties
- Increased enforcement and higher penalties for repeat audit issues
- Penalties imposed by State Gaming Authorities for non-disclosure of federal investigations and enforcement actions
- Repeated references to negative compliance cultures
- Expectations of risk based compliance programs and risk assessments
- Increase in SAR filing
- Increased sharing of information
- New CDD Rules
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- Tips for a successful federal/state regulatory examination:
- Documentation & Reporting;
- Interacting with the Examiners;
- Lessons learned from the Exam experience; and
- Exam Findings/Remediation Activities/Management Reporting.
- Practical AML Policy and Procedure documentation guidance.
- A Compliance Culture all the way to the “top”!
- How to stand out in a “good” way.
- Board and/or Senior Management Buy-In.
- Change Management and effective, proactive, compliance.
Who Should Attend:
- AML Lawyers
- AML Professionals
- Financial Institutions
- Senior Management
- Counsel and Advisors
- Finance Executives
- Casino Owners
- Online Gambling Operators
Allen represents U.S. and foreign-based financial services institutions and commercial clients on regulatory and international trade compliance matters and in ancillary proceedings related to ongoing civil litigation, such as state and federal regulatory enforcement investigations and international corporate investigations. Allen handles issues with multijurisdictional or international implications, such as compliance with requirements of anti-money laundering laws, the Bank Secrecy and PATRIOT Acts, data privacy requirements, import-export issues, and matters involving the U.S. Treasury Department's Office of Foreign Assets Control, the U.S. Commerce Department's Bureau of Industry and Security, and the U.S. State Department’s Directorate of Defense Trade Controls. He has interacted with the Federal Bureau of Investigation, the U.S. Secret Service, state police, the federal Financial Crimes Enforcement Network, INTERPOL, and overseas law enforcement officials in the resolution of several matters. Allen also counsels institutional clients on matters involving government procurement contracts, including application of Federal Acquisition Regulations and Defense Federal Acquisition Regulations, complying with their requirements/investigating suspected compliance lapses, and responding to agency enforcement actions.
Allen represents U.S. and foreign-based financial services institutions and commercial clients on regulatory and international trade compliance matters and in …
As a Director in Navigant's Global Investigations & Compliance Practice, Anne Marie specializes in fraud, corruption and money laundering investigations. She assists companies in strengthening their fraud risk management capabilities, helps international organizations build effective anti-bribery/corruption protocols. Anne Marie also works with financial institutions to assess, create and enhance their anti-money laundering/terrorist financing programs as well as conducts independent investigations, performs gap analyses, and executes risk assessments.
As a Director in Navigant's Global Investigations & Compliance Practice, Anne Marie specializes in fraud, corruption and money laundering investigations. …
Judy is the Committee Chair for the Mortgage Bankers Association of Georgia Compliance and Quality Control Committee; has served as the Compliance and Audit Committee Chair for the Legal League 100; has served as a member of the USFN Legal Issues Planning Committee; and sits on the Bank Counsel Board of the Georgia Banker’s Association. Judy recently participated as a subject matter expert on the SAFE MLO National Test Committee in conjunction with FINRA’s test development team; as well as the MLO Job Analysis Advisory Committee in conjunction with the Conference of State Bank Supervisors/State Regulatory Registry, LLC, as required under Dodd Frank to re-validate the content of the SAFE MLO National Test.
Judy is the Committee Chair for the Mortgage Bankers Association of Georgia Compliance and Quality Control Committee; has served as …
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Method of Presentation:
Experience in gaming law
NASBA Field of Study:
Specialized Knowledge & Applications
NY Category of CLE Credit:
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About Harris Beach PLLC
Harris Beach and its subsidiaries provide a full range of legal and professional services for clients across New York state, as well as nationally and internationally. Harris Beach is among the country’s top law firms as ranked by The National Law Journal and is among the 2016 BTI Elite law firms based on in-depth interviews of more than 600 corporate counsel at the world’s largest and most influential companies. Our clients include Fortune 100 corporations, privately-held companies, emerging businesses, public sector entities, not-for-profit organizations and individuals. Principal industries we represent include education, energy, financial, food and beverage, health care, insurance, manufacturing, medical and life sciences, real estate developers, and state and local governments and authorities.
About Aldridge Pite LLP
Aldridge Pite LLP is a multi-state law firm offering services to financial institutions. The firm’s compliance attorneys have regulatory experience and familiarity with Bank Secrecy Act/ anti-money laundering regulations as well as terrorist financing, compliance checks for law enforcement or otherwise, and general reporting obligations. Our attorneys have experience reviewing and drafting policies and procedures, performing audits/reviews, and communicating with regulators to ensure effective compliance programs and findings. The firm’s attorneys have experience advising financial institutions with high risk, heavy cash businesses, that have an international customer base or operations. Finally, Aldridge Pite’s attorneys have advised entities on various state’s legal requirements for obtaining a license to conduct business, advised during examinations, and assisted clients with ongoing compliance requirements. Aldridge Pite has offices in Alabama, Alaska, Arizona, California, Florida, Georgia, Hawaii, Idaho, Nevada, New Mexico, New York, Oregon, Tennessee, Utah and Washington, several of which states headquarter the top gaming companies in the U.S.