What does the requirement mean that casinos that have automated data processing systems must use their automated programs to aid in assuring compliance?
Answer 23: Casinos are required to “develop and implement” written programs that are reasonably designed to assure BSA compliance with all applicable requirements.70 Effective casino anti-money laundering compliance procedures should include identifying and using appropriate automated systems and programs71 for all applicable gambling operating divisions or departments (e.g., table games, slots, keno, poker), other operational departments (e.g., cage, slot booth), as well as other departmental functions (e.g., accounting, surveillance) to comply with suspicious activity and currency transaction reporting, as well as to maintain relevant records72 for casino accountholders.73 * * * * * Questions or comments regarding the contents of this Guidance should be addressed to the FinCEN Regulatory Helpline at 800-949-2732.
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