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This document describes factors that a casino or card club may need to consider in assessing the effectiveness of its Bank Secrecy Act (“BSA”) compliance program.

The BSA requires casinos and card clubs to develop and implement compliance programs tailored to their business activities and risk profiles.

A casino or card club may not need to address each of the factors described in this document.

Also, a casino or card club should not construe the factors below as exhaustive and the only ones required to be addressed. Elements of a BSA Compliance Program A casino or card club is required to develop and implement a BSA compliance program that adequately addresses the risks posed by its products, services, customer base, and geographical location for the potential of money laundering and terrorist financing.

At a minimum, each BSA compliance program Deficiencies could result in BSA civil money penalties or other enforcement actions.

Also, a casino or card club may need to consider corrective action, as appropriate.

Deficiencies that may warrant taking corrective action include, but are not limited to the following: In conclusion, an effective BSA compliance program should reflect a casino or card club’s products, services, customer base, and geographical location.

It is a sound practice for a casino or card club to periodically re-assess its BSA compliance program to assure sufficiency and effectiveness.

For questions about this guidance, please contact Fin CEN’s Regulatory Helpline at (800) 949-2732.

SAN JOSE — Walking into the new Bay 101 casino in north San Jose feels strangely familiar — yet modern, contemporary and new.

The stylish square lights now change colors as they reflect a warm glow on wood-paneled walls.

Long, spacious hallways lead from one end of the casino to the next.