Bankers Toolbox
Banker's Toolbox: Detecting Crime on the Casino Floor

Held in Las Vegas, the Bank Secrecy Act (BSA) conference of 2014 spelled a disorienting order of change in the casino industry. The Financial Crimes Enforcement Network (FinCEN) announced that casinos would now come under increased scrutiny for compliance with anti-money laundering (AML) laws, reporting, and enhanced due diligence. In fact, casinos have been under greater pressure to form compliance manager teams, assign Title 31 Officers, and patron information-capturing processes, to enable AML operations. Banker’s Toolbox—a company that has amassed 15 years of experiences helping financial institutions automate their risk and compliance processes, capture customer data, and mitigate financial crime by trapping it at the very infancy— turned its attention to the casino industry in early 2017, responding to the burgeoning needs.

Casinos have traditionally relied on highly manual processes with front-of-house employees manually collecting patron information from the gaming floor. While today’s technology focuses on the gaming experience, not many eyes have turned to the inefficiencies in the monitoring of financial crime. Banker’s Toolbox offers a comprehensive data capture and case management system—BAM Casino—a central repository for compliance information that automates complex tasks, allowing casinos’ front-of-house employees to re-focus their resources on the gaming experience while remaining compliant.

The value of BAM Casino lies in its ability to detect suspicious activity from disparate data sources providing casinos with a comprehensive view of their patron activity. The combined data gets fed into BAM Casino, which is integrated with the customer’s patron database and various operating systems. “We don’t just provide software tools; we also work closely with customers to verify the integrity of the data collected within the system to ensure the validity of the patron profiles, monitoring activities and regulatory reporting needs,” explains Brienne Bryson, product manager for BAM Casino.

Following data acquisition, BAM Casino’s secret sauce—multi-layered analysis—takes effect. Banker’s Toolbox has developed a wide range of scenarios, like ‘structuring’ and chip-walking, which warn to the possibilities of money laundering and other financial wrongdoings on the casino floor. Based on customizable parameters and captured information, the system alerts the Title 31 regulatory personnel and risk managers regarding any activity on the gaming floor that is indicative of financial crime. Banker’s Toolbox tailors the technology according to the specific patron sets, high-roller thresholds, and general business of the casino, in order to reduce false positives. “Do you want something out of the box? Or do you want something personalized to your risk profile? With BAM Casino, you now have that choice,” Brienne concludes.

For a specific customer who had their compliance data streaming from slot machines and table games, the granularity of Banker’s Toolbox’s reports proved crucial. The reports generated prior to implementing BAM Casino only showed data for transactions exceeding a certain limit. With BAM Casino, the customer was able to drill down to each penny, generate accurate CTR reports, and focus on strengthening their Title 31 program and necessary investigations, rather than having to audit each piece of the information on the reports manually. Darrin Hanson, Chief Revenue Officer of Banker’s Tools, concludes, “BAM Casino is a compelling product because of our 15 years of experience catching criminals in the act. Now, we have an opportunity to help an entirely new industry that faces the same regulatory and potential penalty burdens that financial institutions have been worried about for decades. We don’t do slot-machines, we don’t offer ATM hardware; we focus on anti-money laundering and Title 31 compliance. That is our emphasis. For anyone that uses our BAM Casino product, they will see the years of AML experience we have poured into it and immediately understand why it is the smart choice.”