PRACTICAL SOLUTIONS
Benefits of automation
By using an enterprise-wide technological
solution, casinos are able to enhance their
analysis of existing internal data, better
monitor their patrons’ activities, and auto-
mate processes, such as required regulatory
filings. Doing so will enable casinos to focus
on identifying and monitoring true risks.
Like other financial institutions, casino
operators are increasingly using technology
to better analyze the large amounts of col-
lected patron data and leveraging this infor-
mation in order to meet their know your
customer (KYC), currency transaction
reporting and suspicious activity reporting
obligations.
Specifically, technology can be used to:
• Dynamically risk rate new and
prospective patrons;
• Synthesize the results of sanctions and
watchlist screening and adverse media
searches;
• Drive a consistent application of
KYC requirements by automatically
prompting or triggering the appropriate
level of patron due diligence measures
to be conducted;
• Monitor transactional activity against
known red flags (e.g., minimal play,
chip walking, bill stuffing) or against
baseline of expected activity within a
particular peer group of players;
• Conduct and document investigations
on alerted activity;
• Efficiently produce and file currency
transaction reports (CTRs) and
suspicious activity reports (SARs);
• Holistically view a patron’s profile,
including their gambling activity and
relevant “AML history” (e.g., prior
CTRs, SARs, date of last KYC review),
across properties; and
• Proactively identify patterns of
transactions, allowing for more
robust due diligence reviews, better
identification of discrepancies in patron
activity, and more informed decision
making.
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Even more importantly, an enterprise-wide
case management module can collect,
aggregate and analyze patron data; there-
by, allowing for consolidation of alerts and/
or cases at the patron level, which leads to
more comprehensive and productive inves-
tigations. In addition, a case management
tool provides enhanced metrics and report-
ing capabilities to AML compliance depart-
ments, as well as a robust audit trail to
evidence and support the conclusions
reached on investigations.
Technology solutions can also provide a
way for casinos to centrally manage their
regulatory reporting. For instance, a tech-
nological solution can allow a casino to
automatically generate requisite regulatory
filings (e.g. , SARs and CTRs) and manage-
ment reports across the entire organization
and facilitate the identification of joint fil-
ings, when appropriate. This enhances a
casino’s ability to share information at the
enterprise level, as well as with regulatory
authorities.
Technology can help casinos
better understand and deal with
the risks present throughout
their organization
Implementing an enterprise-wide
technology-based solution
Over the past year, casinos have begun to
realize the potential and importance of
technology and analytics in combating
money laundering and financial crimes.
Implementing these types of solutions can
help casinos produce more efficient AML
reporting and better analyze and manage
money laundering risk. However, chal-
lenges also exist when trying to implement
an enterprise-wide solution. Automating
manual processes not only exposes anti-
quated processes and business functions,
but requires business teams to be more
flexible, adaptable to change and available
to receive additional training.
Gaming entities are often made up of sepa-
rate properties that are different legal enti-
ties, each with its own gaming license from
its applicable state gaming control board.
ACAMS TODAY | SEPTEMBER–NOVEMBER 2017 | ACAMS.ORG | ACAMSTODAY.ORG
Due to this structure, each property often
has its own compliance function that has
separate and distinct requirements, making
consolidation, standardization and central-
ization of requirements challenging.
Implementing new technological solutions
into existing systems often requires dedi-
cated time and resources to deploy the
solutions across the organization. For
example, data mapping requests associ-
ated with new software implementations
often expose missing, inconsistent and/or
poor quality data, which require additional
support to remediate. However, the amount
of time and resources dedicated to a suc-
cessful implementation is actually an
investment that leads to a reduction in total
resources in the long run.
Although implementing an enterprise-wide
solution has it challenges, casinos can
widely benefit from these technological
advances.
Technology can help casinos better under-
stand and deal with the risks present
throughout their organization, allowing
them to better monitor transactions, conduct
more thorough investigations and produce
accurate and timely regulatory reporting.
As regulators have continued to stress the
importance of maintaining an effective
AML compliance program, automation can
help casinos continue to improve their
efforts in mitigating money laundering and
other financial crime risks.
Vasilios Chrisos, CAMS, ACAMS global
advisory board member, principal—
Financial Crimes Unit, PwC, New York, NY,
USA, [email protected]
Contributing authors: Paul Havalchak,
director, PwC, Las Vegas, NV, USA, paul.
[email protected]
Heather Finlay, manager, PwC, New York,
NY, USA, [email protected]
Allison Wadness, CAMS, manager, PwC,
New York, NY, USA, allison.wadness@
pwc.com