ACAMS: Managing Patron-Related Risks in Gaming
October 3, 2017
Anti-money laundering (AML) compliance in the gaming sector was once again a hot topic during the recent ACAMS Annual AML and Financial Crime Conference. During the keynote session, it was noted that compliance in the industry has improved significantly, with an increasing number of suspicious activity reports (SARs) being submitted to FinCEN—57,000 SARs were submitted in 2017 versus only 27,000 in 2013.
However, the industry must pay more attention to know your customer (KYC), follow documented procedures, keep AML compliance officers involved, and identify customers’ patterns of activity.
Another major concern that was addressed in a separate session is assessing patron-related risks. During this session, the panel—which included senior AML compliance staff from Stations Casino, Caesars Casino and Cosmopolitan Las Vegas—discussed how to verify patron identities, create risk profiles, conduct due diligence on high-volume patrons, mitigate risks and identify patterns such as structuring.
Taking an enterprise approach to patron-related risks
Benjamin J. Floyd, Senior Vice President, AML / OFAC Compliance Officer at Caesars Casino, says that his organization takes an enterprise approach to patron-related risks. They evolved from an ad-hoc approach to one where they focus on high-risk players/patrons. They have also become more sophisticated by using more factors to evaluate risks, and with the data they have collected over the last three and a half years, the casino has been able to focus on high-risk guests, not just the top players.
When discussing how due diligence in casinos differs from in banks, it was agreed that given the volume of patrons and the nature of the relationships, casinos cannot know everyone the same way as banks. According to Paul Camacho, Vice President of AML Compliance at Stations Casinos, the information that is most valuable to law enforcement is in employees’ heads. Transaction information is important, but so too is what hosts learn about the players.
Krystal Saab, Director of AML Compliance at Cosmopolitan Las Vegas, stressed the importance of training employees and of ensuring management builds relationships with hosts, which makes them more likely to share concerns or suspicions about patrons. As noted by the panel, the transaction pattern of a successful doctor and a small-scale fraudster can look very similar, and it is human intelligence that can help tell them apart.
In closing, the panel recommended that risk identification and segmentation should go beyond the top 50 players because many high rollers are good patrons. In addition, gaming should rely on more than one risk intelligence provider so they can verify the data. They should also engage with these providers if they find errors so that the overall quality of the products increase and everyone can work together to reduce illicit behavior.
About Anu Sood
Anu Sood (LinkedIn | Twitter) is the Director Marketing at CaseWare RCM and is responsible for the company’s global marketing strategy. She has over 20 years of experience in product development, product management, product marketing, corporate communications, demand generation, content marketing and strategic marketing in high-tech industries.