Monthly Casino Compliance

Some of you may have noticed the term “AML/CFT” appearing in compliance-related correspondence, job titles or policies & procedures. And you may hear your compliance team using this term, more and more as we move forward. So, what is that all about?

The organization is in the process of replacing the term “BSA/AML” with “AML/CFT.” As you may know, BSA stands for the Bank Secrecy Act and AML, of course, stands for “Anti-Money Laundering.” CFT is a new, updated term which stands for “Countering the Financing of Terrorism.” But why? Why are we making this change?

The AML Act of 2020 will amend the Bank Secrecy Act by, among other things, requiring several changes to the BSA’s AML program requirements. FinCEN (Financial Crimes Enforcement Network), in anticipation of the changes to come, proposed new rules for compliance programs, including the insertion of the term, Countering the Financing of Terrorism (CFT). The purpose of this change is to clarify and streamline regulations and promote consistency across the board. So, our compliance department will be implementing this change over the course of the upcoming year, some of which you may have already seen.

The AML/CFT update affects all aspects of our compliance program; numerous policies and procedures, compliance team job titles, correspondence, and all training courses, just to name a few and it will take several months to fully complete. So, keep in mind, you may see both terms (BSA/AML and AML/CFT) for some time, but rest assured they refer to the same compliance program.

Additionally, everything is still based on the Bank Secrecy Act, and you may continue to see the term “BSA” used in certain instances. The BSA program is not being replaced, just updated or enhanced. Some of you may remember when our program was referred to simply as “Title 31.” Over time, it evolved into the BSA/AML program.

Now you may ask, “How will this affect our processes and procedures or what we are doing regarding BSA compliance? It is largely a name change that has little effect on the actual processes we all follow each day, although it does, and is meant to, bring more awareness and prominence to Countering of the Financing of Terrorism (CFT) which will align with FinCEN’s National Priorities.

If you have any questions or would like more information about the AML/CFT update, please contact your AML/CFT/OFAC Compliance Team (formerly, BSA/AML/OFAC Compliance Team).