🤑 FinCEN Opens with SAR Sharing Guidance for Casinos | Subject to Inquiry

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FinCen is watching casinos that offer sports betting and In March , FinCEN issued guidance further clarifying this point and providing.


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Second, I will discuss how FinCEN's recent guidance on Convertible Virtual Currency is something that casinos need to pay attention to;; Third, I.


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FinCEN Video on Suspicious Activity

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Guidance Subject. Casino or Card Club Compliance Program Assessment. This document describes factors that a casino or card club may.


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Financial institutions' ability to share suspicious activity reports (“SARs”) within the corporate organizational structure serves as an important.


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FinCEN Director Notes Improved Oversight of Cryptocurrency Industry

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On. August 1, , FinCEN published guidance to casinos titled, “Recognizing Suspicious Activity – Red Flags for. Casinos and Card Clubs.” In particular, the.


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However, threshold of $ 1, , FinCEN intends, when appropriate, to Paragraph (a) (2) provides that a provide guidance to assist the casino.


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"There have been some recent changes to casino regulation and FinCEN This guidance furthers that effort and provides all casinos and card.


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NCUA Webinar: How to be in Compliance with OFAC and FinCEN - Part 1 (5/21/2014)

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Online casinos. Additionally, the guidance addresses a number of notable exemptions to the FinCEN regulations, including, among others, those that apply to CVC.


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"There have been some recent changes to casino regulation and FinCEN This guidance furthers that effort and provides all casinos and card.


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This document provides guidance interpreting the requirements of the Bank Secrecy Act ("BSA") regulations1 as they apply to the casino and.


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This applies equally to domestic money transmitters and to foreign-located money transmitters that do business wholly or in substantial part within the United States. For casinos and card clubs accepting CVC from customers either on location or through your mobile applications, you need to ensure that this is accounted for in your policies, procedures, and internal controls—as well as your risk assessments. BSA reporting is essential to these activities. In part, he stressed the value of BSA reporting:. FinCEN is continually looking at compliance across all financial institutions and will not hesitate to act when it identifies financial institutions that violate the BSA. So far, the study has confirmed there are extensive and extremely varied uses of BSA information across all stakeholders including by the private sector consistent with their missions. If you would like to remain updated on these issues, please click here to subscribe to Money Laundering Watch.{/INSERTKEYS}{/PARAGRAPH} The project has included hundreds of interviews with stakeholder groups, including casinos. We already know that BSA data plays a critical role in keeping our country strong, our financial system secure, and our families safe from harm. Money transmitters have their own obligations under the BSA and its implementing regulations, which includes a formal registration with FinCEN. There is a misconception that just because FinCEN has not publicly issued an enforcement action against a casino or card club since last year that FinCEN is not looking at this financial sector. Let me assure you, this is not the case. It is also important to note that not all enforcement actions are public—FinCEN often closes cases with warning letters sent to financial institutions or refers cases to our delegated examiners to conduct additional examinations. Everyone has also agreed that the work of your skilled analysts and investigators as well as frontline staff, such as those working in the money cages at your casinos contributes greatly to the value of BSA reporting. And as much as 24 percent of its investigations involving criminal tax, money laundering, and other BSA violations are directly initiated by, or associated with, a BSA report. Director Blanco next addressed — again perhaps as a defensive measure — the ongoing issue of BSA regulatory and legistlative reform. The project will result in a comprehensive and quantitative understanding of the broad value of BSA reporting and other BSA information to all types of consumers of that information. How will you conduct blockchain analytics to determine the source of the CVC? {PARAGRAPH}{INSERTKEYS}In regards to the issue of new technologies, Director Blanco stated that FinCEN expects that casinos and card clubs are monitoring their sports betting and mobile gaming programs for all suspicious activity, according to traditional AML obligations. Rather, it is likely they are operating as money transmitters. You should also consider how you will review and conduct due diligence on transactions in CVC.