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FinCEN Assesses $2.5 Million in Civil Money Penalties
"This enforcement action reinforces our message to all financial institutions about the importance of having effective anti-money laundering programs," said Robert W. Werner, Director of the Financial Crimes Enforcement Network. "This case involved the absence of an adequate anti-money laundering program, the use of fictitious social security numbers for customer identification, an unreported deposit of $300,000 in cash from a duffel bag, and other suspicious transactions. The facts of this case demonstrate the egregious nature of compliance failures at the casino."
Financial Crimes Enforcement Network – Press Release March 24, 2006
TRAINING FOR THE GAMING INDUSTRY
The risks are huge. Casinos and gaming establishments are particularly susceptible to exploitation by money launderers. The levying of multi-million dollar fines against major casinos in Las Vegas and elsewhere, as well as the prosecution of casino employees serve as warnings that the federal government takes these laws and regulations very seriously. Some other examples of recent cases involving casinos are listed on our Recent Cases page.
Reducing the risk posed by untrained or poorly trained personnel is not just good business; it is the law. Federal Law requires that casinos must create and maintain ongoing anti-money laundering training programs for their personnel. This is where AML AWARE, a group of law enforcement officers and money laundering experts can help. AML AWARE training for your employees will not only fulfill the government regulatory requirements but can substantially reduce your risk both from money launderers and government regulatory action.
ITC has designed training programs that address the needs of the gaming industry, employing the expertise and experience of instructors and course developers with decades of experience in anti-money laundering compliance and enforcement. This background provides assurance that our clients are receiving the best, most appropriate and up-to-date training available. Further, each course is custom tailored to fit the need of the client and never 'canned.' ITC provides on-site, dynamic, and interactive training programs, all using live instructors to give instant feedback, answer questions, and resolve problems during the session. Unlike some training providers that 'can' videos of PowerPoint presentations that are mailed to the client for later use, we give personal and customized attention to our clients. Although we will use online training programs, these would be used to supplement, rather than replace the on-site interaction between trainer and trainee. No other business currently in existence provides this combination of expertise and approach.
AML Awareness Training
”As high-volume cash businesses, casinos are susceptible to money laundering as well as many other financial crimes and were the first non-bank financial institutions required to develop AML compliance programs.”
U.S Money Laundering Threat Assessment - Dec. 2005
The AML Aware program provides integrated compliance solutions for casinos and other gaming establishments. The federal government has deemed the gaming industry to be at particularly high risk for money laundering and Federal Law requires them to establish and maintain anti-money laundering programs. The AML Aware program is designed to protect your business from exploitation by money launderers and provides the sort of anti-money laundering compliance program required by federal law and regulations. This is accomplished by using an integrated approach with five levels of compliance coverage:
- AML Aware on-site training for employees
- On-site training for management and supervisory personnel
- Follow-on training for new employees
- Certification and testing for all participants
- Registry of trained personnel
This comprehensive approach, combined with any other existing compliance programs, provides maximum protection against money laundering-related problems.
Typical AML Aware Program
A typical program would include a One Day Training Seminar, held at the client business of in a suitable nearby facility. Conducted in a seminar or conference setting, the class can accommodate up to 100 employees. The training is actually divided into two sessions. Employees who are in direct contact with casino guests meet in the morning session and early in the afternoon, while supervisory and management personnel meet later in the afternoon. This training is dynamic with video presentations, extensive interaction between the trainers and participants, and exercises to demonstrate money laundering techniques and detection methods.
The second phase of the program covers newly-hired employees and those who did not attend the seminar. This phase takes the form of a video presentation licensed to the client for this purpose for a one-year period. A web-based interactive "virtual seminar" is being developed and will be available late in 2006 or early 2007. Integrated Training also provides the client with certification that its employees have received the AML AWARE training. We also maintain a registry of all those employees who have received the training and will certify to a government regulatory authority that the client has employed the AML AWARE program as part of its overall anti-money laundering compliance strategy.
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