— Formalized a process to share credit information between the credit department and the compliance department to assist in the company’s “Know Your Customer” program.
— Adopted a requirement for compliance to reach out to a customer’s casino marketing host to obtain information. Formerly, that was an informal communication.
— Enhanced due diligence has been ordered annually for the company’s top 25 cash customers in addition to its top 50 customers.
— Created a new procedure to address transactions in excess of $100,000, regardless of whether the customer comes in with large or small bills.
— Formalized a process to escalate reviews within the compliance department for patrons with multiple suspicious activity report files.
— Spending more than $1 million on anti-money laundering compliance.
— Ordered additional enhanced training for casino marketing staff, emphasizing its responsibility to know its customers, including their source of funds, and to report any suspicions to the compliance department.
— Added an awareness campaign for all line-level employees about anti-money laundering compliance responsibilities.