Title 31 AML Compliance Audit

Periodic independent inspection template for auditing a casino's Title 31 anti-money laundering program, including internal controls, employee training, suspicious activity reporting, and recordkeeping.

Audit Scope and Independence

• Audit period and property scope documented
• Independent tester has no operational responsibility for the AML program
• Audit plan includes internal controls, training, reporting, and recordkeeping
• Prior audit findings and corrective actions reviewed
• Applicable gaming and BSA/AML policies obtained for review

Written AML Program and Internal Controls

• Written AML program is current and approved by management
• Program includes customer due diligence and enhanced due diligence triggers
• Cash transaction monitoring controls are defined and operating
• Thresholds, alerts, and escalation criteria are documented
• Segregation of duties exists for transaction review and approval
• Independent testing frequency meets program requirement

Training and Employee Awareness

• Training curriculum covers Title 31 obligations and red flags
• Training is role-based for cage, slots, table games, surveillance, and supervisors
• Training completion rate for required employees
• Training records include date, content, and attendee verification
• Employees can describe escalation steps for suspicious activity

Transaction Monitoring and Reporting

• Suspicious activity review process is documented and followed
• Alerts and exception reports are reviewed on a defined schedule
• Sampled alerts were escalated with complete case notes
• Suspicious activity reports were filed when required
• Reporting timelines met internal policy and regulatory expectations

Records, Retention, and Management Oversight

• Required AML records are retained and readily retrievable
• Management receives periodic AML compliance reporting
• Open deficiencies have assigned owners and due dates
• Corrective actions address root cause and are tracked to closure