Title 31 AML Compliance Audit

It covers the core elements of a casino AML program that are typically reviewed in a periodic independent test: audit scope and independence, written internal controls, employee training, transaction monitoring, suspicious activity reporting, and records retention. It is designed to document whether the program is operating as written and whether exceptions were escalated and resolved. It also helps you track prior findings and corrective actions so repeat issues are visible.

Use it on the cadence required by your property’s AML program and gaming obligations, then align the timing with your internal risk profile and prior findings. Many teams run it annually, but higher-risk operations may need more frequent testing or targeted follow-up reviews. The template is built to support both full-scope periodic audits and narrower interim checks.

The tester should be independent from day-to-day AML operations and should not have operational responsibility for the controls being reviewed. That usually means internal audit, compliance, or an external reviewer with the right gaming and BSA/AML experience. The template includes an independence check so you can document that the reviewer is not auditing their own work.

Yes. It is structured around the kinds of controls regulators and examiners expect to see in a casino AML program under Title 31 and the Bank Secrecy Act framework. It also supports review of training, suspicious activity escalation, and record retention, which are common focus areas in gaming compliance reviews. You should still tailor it to your property’s policies and any state gaming requirements.

Common misses include outdated written procedures, weak escalation criteria, incomplete case notes for alerts, training records that do not prove attendance, and missing evidence that management reviewed open deficiencies. Another frequent issue is inconsistent follow-through on prior corrective actions. The template is set up to surface those gaps in a repeatable way.

Yes. The training section already separates cage, slots, table games, surveillance, and supervisors, and you can add department-specific checks for your operation. You can also expand the transaction monitoring section to include the specific reports, thresholds, and exception queues used at your property. That makes it easier to use the same audit across multiple locations or business units.

An ad hoc review often misses consistency, independence, and follow-up. This template gives you a repeatable structure, clear evidence fields, and a place to track corrective actions to closure. That makes it easier to compare audits over time and show that the program is being tested on a defined schedule.

Attach the current AML program, training rosters, sample alert or case files, escalation logs, SAR support documentation where permitted, management reports, and records-retention evidence. If you find a deficiency, include photos or screenshots only when they help prove the issue and do not expose sensitive customer data. The goal is to make each finding traceable to objective evidence.