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Select a Casino Anti-Money-Laundering Compliance Solution

Your casino is at risk from both regulatory fines and negative media. Protect your casino by selecting a system to support your anti-money-laundering compliance program.

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Contributors

  • R. Sheridan K. Smith, IT Executive, Bermuda Monetary Authority
  • Kevin Huddleston, Partner, Finley-Cook
  • Rachel Loudon, Compliance Manager, Finley-Cook
  • Bill Scheib, Gaming Technical Advisor, Citizen Potawatomi Nation
  • Ram Patrachari, CIO/VP of Information Technology, Viejas Enterprises
  • BJ Bouschor, Vice President of Information Technology, FireKeepers Casino and Hotel
  • Jeffery Crisp, Controller, FireKeepers Casino and Hotel
  • Michael Bevacqua, Compliance Officer, Seneca Casino

Your Challenge

  • Compliance is risk-based, meaning there is no one solution for all casinos. Each casino has to tailor its compliance system to the risks associated with its size, location, regulatory environment, and customers.
  • Regulators expect casinos to use all available resources to identify threats, including all available information and the latest technology to capture it.

Our Advice

Critical Insight

  • AML compliance requires use of all sources of information. This is an opportunity to gather business intelligence on some of your most valuable customers.
  • A casino is a financial institution in the eyes of the regulators. Casinos need to adapt the best practices of banking to the world of gaming.
  • Artificial intelligence and machine learning provide a deeper search on high-risk individuals, but they also create false positives that require analysts to resolve.

Impact and Result

  • Ensure the IT team understands their roles and responsibilities prior to implementation to help ease the transition into this new system.
  • Identify the AML requirements for both know-your-customer (KYC) information and transaction monitoring systems.
  • Use the accompanying vendor landscape to evaluate the leading products in the market space according to your particular risk-based scenario.

Research & Tools

Start here – read the Executive Brief

Read this Executive Brief to understand why anti-money-laundering compliance is important, what the challenges are, and how you can overcome the issues.

1. Launch the AML compliance project

This phase will help you assess your challenges and project drivers, define your risk model for money laundering, and conduct high-level requirements gathering with the stakeholders involved in AML processes.

Guided Implementations

This guided implementation is a seven call advisory process.

Guided Implementation #1 - Define the current state of AML

Call #1 - Conduct a scoping call.
Call #2 - Conduct a SWOT analysis.
Call #3 - Summarize your risk model.
Call #4 - Identify key stakeholders in your AML program.

Guided Implementation #2 - AML vendor evaluation and selection

Call #1 - Review the vendor landscape.
Call #2 - Discuss the best solution based on stakeholder feedback.
Call #3 - Identify requirements.

Onsite Workshop

Discuss This Workshop

Book Your Workshop

Onsite workshops offer an easy way to accelerate your project. If you are unable to do the project yourself, and a Guided Implementation isn't enough, we offer low-cost onsite delivery of our project workshops. We take you through every phase of your project and ensure that you have a roadmap in place to complete your project successfully.

Module 1: Identify Project Drivers

The Purpose

  • Identify the project drivers and challenges for your AML project.

Key Benefits Achieved

  • A 360-degree view of IT stakeholders
  • Clear understanding of the criteria to measure success for AML compliance

Activities

Outputs

1.1

Assess your current AML compliance challenges and project drivers.

  • An assessment of the importance of the project in the context of the larger organization
1.2

Conduct a thorough analysis, including SWOT, as an early step to charting your AML compliance project.

Module 2: Define the Current State of AML Compliance

The Purpose

  • Review the current risk profile of the casino for money laundering.

Key Benefits Achieved

  • Clear understanding of the current state of the AML program

Activities

Outputs

2.1

Review the structure of your casino’s AML risk model.

  • A summary of current risk model

Module 3: Identify Current Limitations and Pain Points

The Purpose

  • Gain an understanding of the pain points and limitations with the current AML processes.
  • Seek out ways for IT to support the AML program.

Key Benefits Achieved

  • Buy-in from the AML stakeholders for IT’s involvement
  • Clear understanding of the high-level requirements for the AML program

Activities

Outputs

3.1

Conduct interviews with the stakeholders involved with key processes in the AML program.

  • An overview of the current AML system
  • Understanding of the challenges the stakeholders face in successfully implementing the program requirements
  • The opportunities for IT to support the existing processes and resolve any outstanding limitations of the current program
3.2

Establish metrics to measure success in both AML compliance and in the project of selecting an IT solution for the program.

  • A list of metrics to measure the success of the project and program

Module 4: Assess the AML Vendor Landscape

The Purpose

  • Consider and understand the AML solution decision tree.
  • Review the AML vendor landscape.

Key Benefits Achieved

  • Understanding of AML vendor profiles and use cases for KYC and transaction monitoring solution providers

Activities

Outputs

4.1

Create initial vendor shortlist.

  • Shortlist of a maximum of three or four potential AML RFP participants

Module 5: Conduct AML Requirements Gathering

The Purpose

  • Conduct AML requirements gathering.

Key Benefits Achieved

  • Alignment between your organization’s key AML solution requirements and those of the shortlisted vendors

Activities

Outputs

5.1

Conduct requirements and specifications gathering to identify optimal components of an AML solution.

  • Requirements and specifications of the target AML solution

Module 6: Create an AML RFP

The Purpose

  • Create an RFP to submit to AML vendors.

Key Benefits Achieved

  • Method to convey your AML program requirements to vendors while following the proposal and procurement steps set by your organization

Activities

Outputs

6.1

Create an RFP to submit to AML vendors.

  • Completed AML Solution RFP Template to document and communicate your AML solution requirements to vendors