Anti-Money Laundering (AML)
For all Century U.S owned and/or operated properties, the gaming regulators promote AML programs that meet the applicable requirements under the United States Code of Federal Regulations, Title 31, and the United States Bank Secrecy Act (“BSA”). Century Casinos, Inc. has developed a comprehensive program and system of internal controls that ensure compliance with all federal and state regulations. The program is based on a risk assessment conducted for each casino property and is reviewed and updated at least every calendar year. The program represents the efforts to prevent, deter, detect, and report money laundering and other financial crimes, which includes but are not limited to, the following:
- Extensive training for all appropriate employees prior to starting work in their respective areas. Such employees will be tested subsequent to training and must receive a passing score to demonstrate an understanding of the regulations. Additionally, these employees will receive annual training and be tested to ensure an ongoing understanding of the BSA regulations and their role in compliance.
- All new pari-mutuel employees and other applicable departments shall receive training to comply with the filing requirements of Title 26 of the Internal Revenue Code relating to a single cash payment or a series of payments for a transaction for a non-gaming amenity (e.g. hotel block, conference booking, race claiming horse sales) that accumulates to more than $10,000 per patron per 12 month period.
- Employees are made aware that civil and/or criminal penalties may be assessed by the Federal Government for willful violations of these procedures against the licensee, as well as any officer or employee of the company that participated in the violation.
- For casinos that have automated data processing systems, the use of automated programs is utilized to aid in assuring compliance with CTRs and SAR. Everi Compliance™ is an automated system that allows cash transactions to be recorded and compiled for CTR filing and automatic tracking of transactions. Everi is utilized by Century Casino Cape Girardeau, Missouri, Mountaineer Casino, Racetrack & Resort, West Virginia, and Nugget Casino Resort, Nevada.
- Independent testing at the properties is conducted at least quarterly by the property’s compliance personnel. The scope and frequency of the review and testing are commensurate with the risks posed by the products and services provided by the casino. In addition, Internal Audit will perform a semi-annual inspection for the Caruthersville and Cape Girardeau, Missouri properties and an annual inspection for the Mountaineer, West Virginia property. Colorado Compliance personnel will perform an annual inspection of each other’s property.
- Each property is responsible for the formation and maintenance of a SAR committee to review suspicious activity at the property. SAR Committee meetings are scheduled for every two (2) weeks.
- The Know Your Customer (KYC) procedures will require each casino to review a set number of high-volume patrons as defined in their risk assessment. The property maintains the reported high-volume top patrons on a master listing over the course of a calendar year to identify any patron trends that could lead to AML/BSA violations. The KYC customer listing is discussed at least quarterly in the property’s Compliance and/or SAR Committee meetings.
In Alberta, Canada the Alberta Gaming Liquor and Cannabis Commission (AGLC) has assumed responsibility of acting as the compliance entity for ensuring that casinos and racing entertainment centers meet the obligations of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). FINTRAC has required through legislation that all entities conducting financial transactions, including casinos and racing entertainment centers, must be responsible to report all transactions meeting select criteria in an effort to detect and prevent money laundering and terrorist financing. The Facility AML requirements are:
- Casinos and REC facility licensees are responsible for the submission of all Receipt of Funds Transactions (ROFTS), Large Cash Transactions (LCTs), Casino Disbursements (CDs), Unusual Transactions (UTs) (completed or attempted), and reporting all incidents related to property owned or controlled by or on behalf of, a terrorist or terrorist group to the AML unit.
- Facility licensees must appoint an AML liaison responsible for facility compliance and AML administrators for data entry into AGLC AML Reporting System.
- Casino facility licensees must develop and maintain internal AML facility policies and procedures.
- Casino facility licensees must use the PTR (Customer Transaction Report) to record all reportable and receipt of funds transactions.
- Casino gaming workers require AML certification through AGLC's training program.
AML certification is the AGLC's Anti-Money Laundering training program. The program has been developed to educate all registered casino gaming workers within Alberta, including specified AGLC employees, on the topic of Money Laundering. The information in AML Certification provides all Registered Gaming Workers with exposure to the possibilities of money laundering related to cash transactions within a casino environment. AML Certification is mandatory for all individuals exposed to the potential risk of money laundering or terrorist financing activities within a casino or REC. This includes Registered Gaming Workers who are employed in a casino or Racing Entertainment Centre and key personnel of the AGLC. It is conditional for all Registered Gaming Workers registration to have valid AML certification. All Registered Gaming Workers are required to recertify every 2 years.