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The Compliance Game The protection afforded by compliance software is needed now more than ever By Dave Bontempo
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ay friendly entities now, or unfriendly ones later. Casino operators increasingly grasp this message regarding the pivotal gaming compliance sector. The era of colossal growth, numerous government regulations and the Covid-induced staff shortages has them chasing their own paperwork. Operators see the need to catch it. Via due diligence and by hiring outside vendors, casinos suffer fewer high-profile incidents like The Big One. That was a $75 million fine levied against the Tinian Dynasty Resort and Casino in the Northern Mariana Islands for Bank Secrecy Act violations by the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) in 2015. Yet even the “lesser” violations (Atlantic City’s Trump Taj Mahal was fined $10 million for violations of the Bank Secrecy Act in 2015) can hurt an operator’s bottom line and reputation. Casinos understand the importance of customer identification and verification, currency transaction reports, record-keeping, and the realization that Title 31 is serious business. Fortunately for them, industry specialists can address the dilemma.
The VIP Shield Company officials contacted by GGB stress how the casino gaming industry is one of the most regulated industries in the country. Operators must ensure state regulations are met along with those outlined on the federal level. Of these, Title 31 of the Bank Secrecy Act includes a few considerations operators must meet pertaining to antimoney laundering (AML) regulations. At a minimum, Title 31 requires every casino’s AML program to provide for all of the following: • Internal controls (policies and procedures designed to assure compliance with Title 31 and the Bank Secrecy Act) • Continuous training of casino 94
Global Gaming Business OCTOBER 2021
employees, including identifying unusual and/or suspicious transactions • Independent testing for compliance, the scope and frequency of which correlated with the specific casino’s money laundering and terrorist financing risks • A compliance officer responsible for day-to-day compliance with Title 31 and the casino’s AML program • Procedures for using all available information to determine, when required, the name, address, and Social Security Number (SSN) of a person, as well as to verify their identity • Procedures for using computers to aid in assuring compliance if the casino has computerized systems • Procedures for using all available information to determine any transactions or patterns of transactions required to be reported as suspicious Global Payments Gaming Solutions’ VIP Shield is designed to help operators adhere to these standards. VIP Shield provides casinos with a new level of compliance assistance by automating anti-money laundering and IRS reporting processes, including multiple transaction log (MTL), negotiable instrument log (NIL), monetary instrument log (MIL), chip log transactions and suspicious activity reporting (SAR). The configurable, web-based solution provides custom reporting to isolate risk potential while automating 90 percent of MTL transactions, empowering operators to focus on their patrons. Company sales pitches encourage operators to stop manual compliance processes that jeopardize their business. Accessible directly through Global Payments’ VIP LightSpeed platform, VIP Shield automatically flags transactions for necessary compliance actions and posts chip log entries as needed. The solution also executes SAR and incident reporting as needed.
