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Leadership Compliance Efforts, leadership needs to understand why the BSA covers casinos.
This means having the authority to decide issues including, but not limited, to: Filing SARs; Excluding patrons from the casino based on money laundering risk;5.
This committee should meet at least quarterly and review reports from the BSA officer on the status of the program.At a minimum, the risk assessment methodology needs to include five key action items: Identify the business segments, business units and support functions to be assessed.From a risk management perspective, casinos would be wise to develop and implement programs to ensure that all employees fully understand their institutions AML obligations.Unfortunately, this creates a silo culture.Some view the technology solutions as cost prohibited.Historically, systems utilized by the gaming industry to detect suspicious behavior have not been held to the same rigorous standards as in the banking industry.The BSA officer may want to consider disseminating the information sas silver bonus lounge in the following components: New employee orientation.An organizations top leadership must set such culture.
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