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Online Training Title 31 Lesson 1

Lesson 1
by

BHCR Compliance

on 26 March 2015

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Transcript of Online Training Title 31 Lesson 1

Illegal Activities
Three Steps
Title 31
The income tax law is a lot of bunk. The government can't collect legal taxes from illegal money
-Al Capone
Terms & Concepts
History
Money Laundering
1970
Currency Transaction Reporting for banks
1985
Currency Transaction Reporting (CTR) for casinos
1988
Anti-Drug Abuse Act
Monetary Instruments over $3,000
1996
CTR's for Tribal Gaming
2002
Suspicious Activity Reporting (SAR) for casinos

1. Placement
Money launderers will place their money within financial institutions, including casinos, without arousing suspicion
2. Layering
The money will move through various transactions, so the original source of funds is difficult to identify
3. Integration
Money goes back into the financial or business system so it appears as fair earned funds/assets.
$1.25
December 2009
Vol X, No. 1021
Overview
Government Agencies
Four Reasons
Reasons to Follow
Money Laundering
Occurs when criminals try to hide their source of funds. If successful, it may appear as if their funds were fairly earned.

Terrorist Financing
An act that unlawfully and willfully provides or collects funds with the intention that they are used, in full or in part, to carry out an act of terrorism

I
llegal Activity Involves:
Organized Crime
Illegal firearm sales, smuggling, and the activities of organized crime (i.e. drug trafficking)
White Collar Crime
Embezzlement insider trading, bribery, mortgage and computer fraud schemes
May create an incentive to hide source of funds

Tax Evasion
The Act or instance of refusing or failing to pay all or part of taxes.
Perform assigned duties with confidence and a clear understanding of Title 31 requirements

Prevent criminal activities from occurring at our workplace and in our communities

Help assist in the protection of the United States financial system

Avoid significant fines and penalties that can result in noncompliance with Title 31
BHCR Title 31
What can employees do?
Unusual Activities
If you observe an unusual activity, immediately report them to a Supervisor, Manager, or a Compliance Supervisor.


Violations
Fines
Willful Violations
Title 31 Anti-Money Laundering Program
Fines up to $250,000;
Up to a 5 year jail sentence or;
Both
Fines up to $500,000;
Up to a 10 year jail sentence or;
Both
Applicable when violation is part of a pattern of any illegal activity involving $100,000 in a 12 month period
Confidentiality:
FinCEN (Financial Crimes Enforcement Network)
To enhance the integrity of financial systems by facilitating the detection and deterrence of financial crime

IRS (Internal Revenue Service)
Nation's tax collection agency and administers the Internal Revenue Code enacted by Congress

Bank Secrecy Act
Established requirements for recordkeeping and reporting by private individuals, banks, and other financial institutions.
Objective was to identify the source, volume, and movement of currency and other monetary instruments

Government's Mission
Safeguards the financial system from terrorist financing, money laundering and other illegal activity
Can be assessed to
The Casino, Employees, Officers, Directors, and Partners

Structuring a transaction
to avoid reporting can range up to the transaction amount
Structuring occurs when one or more patrons conducts or attempts to conduct one or more transactions in currency to evade the reporting requirements

Disclosing information
about an unusual activity report can range from $25,000 to $100,000

Only share unusual activities with authorized personnel such as your Manager or Compliance Supervisor. It is illegal to talk about this information with coworkers, family members and customers.
Reporting
Help identify potential and actual illegal activities such as money laundering, financial fraud, and other illegal activities.

Detect and prevent the flow of illegal funds and help identify the threats and patterns of illegal activities

Help protect BHCR from fines and penalties associated with non-compliance.


Patrons
Patrons should never find out that someone reported unusual activities. By law, you are not allowed to advise the patron, other employees, or anyone else that is not authorized personnel, that an unusual activity was reported.

Expensive fines may be subjected to any employee if they disclose information.


Title 31
a United States Federal regulation that requires Casinos to report certain cash transactions and unusual activities to the government.
You are now done with the presentation. To take the quiz, close out of the presentation. Go back to the PolicyTech page and hit "Marked as Read" at the top of the page. It will prompt you to take a quiz, which you are required to pass to complete the training.
How Title 31 Affects Casinos
Requires reporting certain currency transactions to assist government agencies in uncovering money laundering activities and other financial crimes.
Full transcript