Compliance & Ethics Professional - Society of Corporate ...

FeatureRole of compliance manager in a casino worldAs a Casino Compliance Manager who overseesa Compliance department, I must befamiliar with the laws that govern the casinooperation and understand what gaming regulatorsrequire. Many times it can be a worldof chaos where we are confronted with tryingto accommodate many layers of regulations.I frequently have to review if a particularactivity, game, or promotion is done properlyunder federal law. Yes? Okay, then whatabout state law? Yes? Okay, then what aboutthe MICS, the Tribal State Compact, the TribalOrdinance, and company policy? A lot ofchecking and double checking is done to seethat all the rules are followed and all the regulationsare satisfied.Communication skills to work successfullywith gaming regulators, inspectors, and theoperation are imperative, because I act as theliaison between the operation managementand the regulators. I must be able to coordinatecompliance across various departments,manage each department’s different internalcontrols, and ensure that they are kept up todate and in line with the many regulations.My Casino Compliance department investigatescompliance issues, ensuring that anyproblems with gaming compliance are rectifiedas quickly as possible. We also oversee therules of all casino promotions and contests toensure the integrity of each one.It’s not a perfect casino worldAs a new Compliance Manager, I frequentlyreferred to SCCE documentation and literature.Once I realized how useful and relevantthe information was, I became a member ofSCCE and then earned my CCEP to establishcredibility in this field. The one area I havetrouble finding information on is specificcasino-related topics in relation to compliance.The following three come to the forefront on aregular basis.“I frequently have to review ifa particular activity, game, orpromotion is done properly underfederal law. Yes? Okay, thenwhat about state law? Yes? Okay,then what about the MICS, theTribal State Compact, the TribalOrdinance, and company policy?”Bank Secrecy Act (BSA), Title 31.Casinos are considered financial institutions.Certifications, programs, seminars,and webinars in anti-money laundering areoften focused on the banking industry. Thebest source for casino compliance managersis directly from the Financial CrimesEnforcement Network (FinCEN) and the IRS.Networking with others in the industry isanother good resource.In a casino, the scenarios that arise forsuspicious activity reporting are not commonoutside of the gaming industry and, therefore,become a gray area when looking forcomparisons and points of reference. Issuessuch as patrons switching seats when hittinga jackpot or redeeming chips at several differentlocations are not identified in anti-moneylaundering sources.Another challenge involves the many positionsin the casino that require training in theBSA. As Compliance Manager, I am responsiblefor seeing that 86 different positions arebeing trained on how to recognize and reportmoney laundering. This is a daunting task,because it is not a one-size-fits-all program.Each position needs to know varying degreesof information. Extended training sessionswith too much information are costly in termsof the employees’ time, and employees tend tolose interest when the training is too lengthyor inapplicable to them.Compliance & Ethics Professional March/April 2012+1 952 933 4977 or 888 277 4977 | www.corporatecompliance.org 33