Tag Archives: title 31 compliance

Create a Title 31 Program You Can Be Proud Of

According to Grant Eve, partner at Joseph Eve, there are 3 stages of money laundering:

  • Placement
  • Layering
  • Integration
3 Stages of Money Laundering, courtesy Joseph Eve

The “placement” of the funds into a financial institution is the first stage of the money laundering process and this is the stage where casinos are most vulnerable. A comprehensive title 31 compliance program is vital in order to prevent “placement”. FinCEN is authorized to assess civil penalties against casinos and employees thereof for willful violations of the anti-money laundering program, reporting, and record keeping requirements.

Components of a successful title 31 compliance program that can prevent non-compliance, include but not limited to:

  • Written system of internal controls
  • Internal and/or external testing for compliance
  • Training of casino personnel
  • BSA compliance officer
  • Use of title 31 compliance software to aid in assuring compliance

For a detailed presentation on title 31 compliance & recent developments and help with your title 31 compliance program, see Grant Eve’s presentation from NIGA 2012:

Get Rid of Title 31 Non-Compliance Once and for All

Today marks the end of paper SAR (Suspicious Activity Report) and CTR (Currency Transaction Report) filings! FinCEN requires that these forms be electronically filed and will no longer accept paper filings. Non-compliance will result in fines that could number in the hundreds of thousands of dollars.

CHEETEYE engineers have been working around the clock to make sure that our users are in compliance with the new FinCEN title 31 requirements. In addition, our users will benefit from the software automation that has been built into the software to handle many of the title 31 changes that require extensive data entry on the BSA site. Take a preview of our user friendly title 31 software tool!

If you want to get rid of title 31 non-compliance once and for all, contact us at: 720-221-6915 or info@cheeteye.com

FinCEN Alert

It’s been a very active year for CHEETEYE so far. We have attended and exhibited at 3 conferences starting with ICE in London, followed by World Game Protection in Las Vegas and finally NIGA in San Diego. The experience we gain at these conferences helps towards keeping CHEETEYE ahead of the pack. At NIGA last month I attended a Title 31 compliance presentation by Grant Eve. The very informative presentation, which can be viewed below (courtesy of Joseph Eve CPA’s), helped us ensure that we have everything covered for the Title 31 changes required by FinCEN.

We will be sharing more conference highlights over the next few weeks. At the end of the month we head to G2E Asia in Macau to gain some insight from the gaming boom taking place in Asia.