Developing and Maintaining AML Regimes for Gaming Institutions of All Sizes – ACAMS 2016 Panel
Las Vegas is a city defined by its casinos. But the tall towers, sprawling properties and seemingly unlimited stream of income are far from the norm in the gaming industry, particularly when tribal gaming and small independent casino operators enter the conversation. And by that same note, anti-money laundering (AML) regimes differ from casino to casino as well. This was the focus of today’s panel, “Developing and Maintaining AML Regimes for Gaming Institutions of All Sizes,” at ACAMS 2016.
As Derek Ramm, director, AML, Alcohol and Gaming Commission of Ontario (Canada), noted, enacting AML processes at a casino is not only than a financial issue, but a reputation issue as well, and one that gaming institutions have taken notice of.
The biggest challenge that gaming institutions face today is – as Benjamin Floyd, CAMS, senior vice president, AML/OFAC Compliance Officer, Caesars Entertainment, described – a “war on talent.” Larger gaming institutions can afford to centralize AML functions and staff them appropriately with former law enforcement, financial industry veterans, and so on. But that’s not where the challenge ends.
As Floyd notes, these organizations still tend to be understaffed because, simply put, “they’re not established to make money.”
In some sense, this is where smaller gaming institutions may have an advantage over a large casino business with several locations across several jurisdictions. But this doesn’t begin to account for the largest challenge of all – building and managing AML structures in a business that draws customers from all walks of life.
As Floyd noted, his organization has mechanisms that can track guests and verify/assess their source of income. For larger gaming organizations, risk can be assessed on a more centralized basis.
For smaller gaming organizations, Ramm noted that player loyalty programs are often the best way to track player activity. The question turns to what triggers an investigation of a customer.
The panel cited “chip walking” as an area of concern – a practice where an individual will buy chips at a gaming table with illicit cash, play for a brief time only to leave the game and cash the chips in for a check and thereby legitimize the funds. Is that player a drug trafficker or a high-roller? In the end, casinos must rely on their systems to decide who is who.
As Cynthia Santana, supervisory special agent with the FBI remarked, “It’s not against the law to be reckless with your money, but it is against the law to willfully hide earnings.”
Oftentimes, Santana added, perpetrators of other financial crimes, like insurance fraud, commit these acts to fund their gaming habits. This is where collaboration with other AML professionals can be helpful in identifying and apprehending criminals. This is where, as Floyd noted, education and communication between law enforcement, compliance teams and casino ownership is key to confront these risks.