“If you think compliance is expensive, try noncompliance.” – Paul McNulty, Former U.S. Deputy Attorney General.
Vector Solutions hosted Joseph Busby – Chief Compliance Officer of Foxwoods Resort Casino, special webinar presentation Making the Case for Compliance: Balancing Operations, Finances and Staffing with Compliance where he discussed the challenges balancing operations and compliance against the bottom line.
The presentation was directed to AML compliance but the tips can be applicable across the gaming industry. We had over 100 registrants. Those in attendance included, gaming industry compliance professionals, banking industry professionals, regulatory & law enforcement individuals, casino vendors and CPA firms. Joseph presented this topic at our Regional Oklahoma AML Seminar this past February, but it’s even more relevant now as casinos struggle with reopening, budgets and staffing concerns.
The topics covered in this webinar included:
- Adding Value to a Cost Center Department
- AML Compliance Staffing
- Encompassing Regulatory Requirements through an Operational Lens
Adding Value to a Cost Center Department
It is difficult to measure the cost of non-compliance since the Civil Monetary Penalties (CMPs) fines have a wide range. It is important to be aware that even with shut downs, Casinos should remain mindful of compliance. Properties are still being audited. The IRS is looking for AML compliance with the data that was available prior to the closure. Remain vigilant and adhere to the AML guidelines and requirements.
Be sure to remind the executives that AML compliance is federally mandated when Compliance teams are being asked to justify what they are doing with the staffing, budgeting and operations. Eliminate “busy work” related to compliance to be efficient. This adjustment will reduce labor costs while reducing the burden on the operations and compliance staff. Remember, don’t let the policies and procedures become a problem to the compliance.
AML Compliance Staffing
When it comes to budgeting for the compliance operations and staffing, the rule of thumb is to staff according to the actual needs rather than to justify the existence of AML compliance. Think of this practice as risk based. The risk assessment standpoint addresses the AML program and the staffing.
While hiring, it’s important to emphasize the training, experience and additional AML related certifications. Training is crucial to expand the view of the overall compliance function and how all departments are connected. The compliance function will add more value to the organization and make more of a compelling case when the staff has required training and beyond with certifications, such as the Institute for Certified Gaming Industry Professionals – Gaming Anti-Money Laundering Specialist Certification.
Encompassing Regulatory Requirements through an Operational Lens
Valid identification is generally required throughout the compliance process. Leveraging other departments to assist with compliance will help make the case. If a patron claims they don’t have a valid ID on them, the organization can use the following departments to receive the required information – Players Club, Slots, Cage, Host, Hotel, and non-gaming purchases like, restaurants, show tickets, gift shops, etc.
Joseph emphasized working with other departments to assist with the compliance function. This ensures the positive guest experience remains and is all tied to creating an efficient and effective compliance function to show the value added.