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Risky Business: Meeting the ISO 9001:2015 Risk Requirements in the Gaming Industry

Presenter: Laura Denktash, Performance Excellence Manager, VGT - An Aristocrat Company, Tulsa, OK, USA

Keywords: Regulatory Compliance, Gaming Industry, Risk-Based Thinking

Industry: Manufacturing, Software, Gaming

Level: Intermediate


ABSTRACT 

Casino games provide billions upon billions of dollars of profits each year. Risk exists at every step of the operation and can cause the casino or gaming company to lose its gaming license. What is a casino license worth? To a gaming company, the answer is simple: everything.

Regulatory compliance programs in the gaming industry are an insurance policy for a company’s future. As 24/7, cash-intensive operations, casinos are natural targets for money launderers. Like banks, U.S. gaming operations are required to file Currency Transaction Reports whenever patrons pass more than $10,000 over 24 hours, and Suspicious Activity Reports (SARs) when the property “knows, suspects or has reason to suspect” that a transaction of at least $5,000 involves funds derived from illegal activity. To keep ahead of money launderers, the American Gaming Association (AGA) released a list of best practices. No matter how tight the controls, criminal syndicates, cartels and garden-variety crooks will always be working on new ways to clean dirty money obtained from drug trafficking, human trafficking, Medicare fraud, ID theft, mortgage fraud or other nefarious activities. Once obscured, tainted profits can re-enter the economy, and the money launderers subsequently “make out like the bandits”.

What are the basics of an effective Anti-Money Laundering (AML) compliance program? It’s must be risk-based, and designed to reasonably detect potential money laundering at a given casino.The Financial Crimes Enforcement Network (FinCEN) has also made it clear that training from the top down is important. FinCEN is a bureau of the US Department of the Treasury that . It collects and analyzes information about financial transactions in order to combat domestic and international money laundering, terrorist financing, and other financial crimes. FinCEN has made it clear that training from the top down is important.