Title 31 audits for Tribal casinos

What the regulation requires

Tribal gaming operations with more than $1 million in gross annual gaming revenue are treated as casinos under the Bank Secrecy Act. Under 31 CFR 1021.210, each must maintain a written compliance program that includes internal controls, independent testing, training, a designated compliance officer, procedures for using all available information, and automated systems where the casino uses them.

The rule calls for the scope and frequency of independent testing to match the money laundering and terrorist financing risks of the casino’s products and services. A Title 31 audit is that independent test.

What we test

• ✓
  Currency transaction reporting. Aggregation of cash-in and cash-out activity, multiple transaction logs, and timely, complete CTR filings.
• ✓
  Suspicious activity. How unusual activity is identified, escalated, reviewed and reported, and how decisions not to file are documented.
• ✓
  Customer identification and recordkeeping. Identification and verification when required, and retention of the records the regulations call for.
• ✓
  The flow of transactions. Cash activity traced across cage, table games, gaming machines and kiosks over sample weeks.
• ✓
  The program itself. The written program, risk assessment, compliance officer role, training records and use of automated systems.

What you receive

A report of exceptions tied to the regulation, separated from recommendations, written for management, the compliance officer and the Tribal gaming regulatory authority. The results also give you a documented basis for the program when it is examined.

How the engagement runs

1. Program review

   We read your written compliance program, risk assessment and procedures, and interview the compliance officer about how they work in practice.

2. Sample selection

   We select sample periods in seven-day increments so cash activity can be followed from one gaming day to the next.

3. Transaction testing

   We trace cash activity across the cage, table games, gaming machines and kiosks to the multiple transaction logs, CTRs, the negotiable instrument log and SAR decisions, and test training records.

4. Report

   Exceptions are tied to the regulation and separated from recommendations, in a report for management, the compliance officer and the regulatory authority.

Questions