Title 31: Suspicious Activity and Anti-Money Laundering at our facilities

(Annual Refresher Course)

You’ve done a great job at CNE! And it shows! People are visiting our properties in droves
and having a great time! …even the bad guys.

Criminals love casinos!

They love the hotels, the multiple dining options and the live entertainment! But they’re
also drawn to the casino industry because of the large amounts of money that flow through
them every minute of every day.

They love the fact that the majority of our casinos are open 24/7, 365 days a year and that
they do a lot of the same types of currency transactions that banks do:
 Breaking bills (currency exchanges)
 Check cashing
 And credit card advances
They know we have a lot of cash moving in and out because our offerings involve tons of
cash, making it easier for the true nature of money to be masked; which is why casinos are
a magnet to criminals who are primarily involved in financial crimes such as money
laundering, tax evasion and fraud.
They have a perception that it’s easy to launder money at casinos so they attempt to use
our casino’s financial services as a front to convert the money they’ve ‘earned’ from their
illegal activity… into “clean” money by spending it on gambling and entertainment – just
like our other guests are doing.
Their hope is that they’ll blend in, making it difficult for us to distinguish between their
“laundering of funds” and all of our other casino guest’s activity.
So, every casino is potentially at risk of:
 Being used for illegal purposes
 Accepting money that these criminals obtained illegally
Money laundering is one of the reasons that the U.S. gaming industry is one of the most
heavily regulated and controlled business sectors across the globe; subject to federal anti-
money laundering requirements.
So, in an effort to help you become even more aware of the type of unlawful acts these
crooks try to pull off… we’ll be pointing out CNE’s best practices in this refresher training for
Title 31 Compliance.
Our goal is that it will help ensure that you have a better understanding of what money
laundering is and how to fully comply with the regulation.
This is important, due to the staggering potential cost to you and the company… of just one
instance of non-compliance.

Existing culture of compliance

You’ve been working in an environment that promotes and fosters a strong and positive
culture of compliance. A culture, centered around doing everything possible to insure
money laundering is identified at our properties.
And everyone at CNE is dedicated to the same goal; from the top, down. Our leadership
supports us in our quest to be compliant with the regulations because it’s essential to the
casino industry and frankly… because it’s the right thing to do.
For instance: Backing our employees by staffing property Compliance Officers that are not
only dedicated to assisting the casino in managing risk, but who make themselves available
whenever necessary as someone you can ask compliance-related questions and report
problems that are related to Title 31:
o Policy
o Training
o The EVERI system
o Suspicious Activity Reporting
And the most significant part of our culture of compliance is made up of people like you who
work to identify and report suspicious activity every day.
So, you’re already familiar with the basic individual obligations of what is required to meet
the regulation. Now it’s….

Time to kick things up a notch

Now our plan is to help take you to the next level – to better arm you with the knowledge
you need to get even better at identifying suspicious activity. And the way we hope to do
that is by talking about it more in-depth as to how it relates to your job on a daily basis.
Realizing… that it’s not only about meeting all the requirements (basically checking all the
boxes), its ensuring that you have the knowledge to identify and report every single
suspicious activity that’s coming through; because there may be activity happening at your
property that you may not have thought of before as being suspicious.
So, in today’s training we’ll be:
 Briefly covering the requirements, and help you understand why we have those
specific controls in place
  We’ll give you a little more background about Title 31
 And… we’ll cover the compliance-related issues (and respective solutions) that are
reported as being the most common among CNE properties

Let’s begin with what you already know:

By now you’re already familiar with the fact that Title 31 is a federal statute known as The
Bank Secrecy Act (BSA), an anti-money laundering (AML) program that was created to track
and prevent money laundering and tax evasion.
And… you’ve learned that there are essentially two main requirements to that statute:
1. Reporting suspicious activity (SARs)
2. The tracking and reporting of cash transactions at our casinos

1. Identifying suspicious activity

Now let’s dive deeper into how to calculate risk.
 Ever see something that seemed out of the ordinary?
 Or see something that seemed out of place?
 Something that made you question what a guest was up to?
 Ever notice unusual patterns of a guest’s behaviors?
o For example:
 They increased their betting or cash transactions significantly without
explanation
 Or have you seen someone suddenly change the methods used for
bringing money in or out of the casino?
 Perhaps you’ve seen someone:
 Requesting multiple checks or cash
 Or… someone wanting to break the money up in multiple ways
as payment for their jackpot or a table games win
 Or… maybe it’s something you just couldn’t quite put your finger on, but something
in your gut told you that it didn’t seem right.
All of these actions or practices may be entirely legitimate, but we should pay attention to
the fact that they may not be.
The following are some of the most common types of suspicious activities noted at our
facilities:
 Verifying ID’s:
o Fake and Fraudulent ID’s: When you’re handed an ID, take a moment to
make sure it looks and feels right. These are all the type of things that you
should be looking for:
 Picture:
 Is the picture blurry?
 Is it faded or peeling off?
 Text:
 Does the text look right?
 Does it appear blurry or faded?
 Overall look and feel:
 Are there peeling corners?
 Are the edges frayed?
 Is the lamination is peeling?
 Is the ink bleeding?
 Do you notice incorrect
information on it?
 Is the state spelled correctly?
 If you suspect that you have been presented a fake ID, refer to the ID
Checking Guide and get Security involved so they can help verify it.
o Foreign ID’s: We accept most (but not all) types of foreign ID’s. It must be a
government-issued photo ID, even if it’s a foreign government. Refer to the
ID Checking Guide
 Scenario: Someone from Guatemala presents their chauffeur license
(which is basically a company work badge with their picture and
company name on it) as their ID.
 This is NOT an acceptable ID because it is NOT a government-
issued photo ID.
o Unfamiliar ID’s: If you are presented with an ID that you haven’t
encountered before, please refer to the ID Checking Guide to ensure that the
ID that they’ve given you, matches what the example is in the guide.
o Not being able to determine if it is an accepted form of ID:
 Don’t just visually look at the ID and guess whether it is acceptable
because visually it may look ok to you (and it may be a legitimate
identification, but just not a form we can accept.)
 Examples: Military or government employee ID’s
  So, again… if it is a form of ID that you are not familiar with…
confirm that the ID is an acceptable form by looking at the ID
Checking Guide.
 You can also contact your manager, Security or your site
Compliance Officer if you have any questions.
 Multiple ID’s with different information
o Duplicate accounts
o Multiple patron accounts
 False and Conflicting ID’s
o Name on the ID doesn’t match the name on the social security card
 Tax Numbers and Identity Theft
o Photo doesn’t match the card holder
 Seat switching:
o Ever witness (or suspect) a seat switch on a jackpot?
 Structuring:
o An act of hiding or attempting to hide (or disguising) financial transactions in
order to avoid Title 31 record keeping, such as numerous currency exchanges
from the same individuals.
 Enlisting an agent to assist in evading Title 31 reporting
 Failed patron validation:
o For example: Fraudulent SSN’s
 If any one part of the patron validation fails and we’re unable to
validate:
 OFAC: Follow the procedure in the OFAC policy and immediately
contact Compliance
 Tin Check or the Death Master List (DML) fails: a SAR may be
warranted
 Fast feeding:
o It is every employee’s responsibility to monitor for fast feeding.
o Report if fast feeding is identified.
 Suspicious Currency Exchanges:
o Large currency exchanges
o Currency exchanges without utilizing casino offerings
o Or currency exchanges involving multiple people
 Source of Income: Please be aware if a guest’s gaming activity (level of play) is not
supported by their known income.
Remember to report any suspicious activity.
 And, please help shave unnecessary time off of the process by including as much
information from all the guests involved and explain everything in the narrative section of
the report… because if you don’t gather that information up front… it can cause a lot of
additional work for the Compliance Officer because they then have to gather it after the
fact, which includes:
 Frequent follow-ups such as making multiple calls and sending numerous emails to
several departments; including Revenue Audit and Surveillance
 And waiting for employees to get back to work so they can answer questions
If you have any questions or need more information, contact your site Compliance Officer.

Real-life examples of when customer transactions would trigger a Suspicious Activity

Report:
 A customer buys into a blackjack game with a large amount of cash that reeks of
marijuana. He plays a few nominal hands then takes the chips to the cage and either
cashes out or asks for a check.
o Triggers: Large game buy-in, suspicious odor on currency, minimal gambling
activity, quick cash out
 A customer goes to various slot machines putting cash in the bill acceptors, collects
cash-out tickets totaling large amounts with minimal gaming activity, then cashes out
at the ticket-cashing kiosk, the casino Cage… or asks for a check.
o This is often known as “bill stuffing” or “fast-feeding”
o Again, large cash transactions with little gaming activity should trigger a
Suspicious Activity Report
 A customer goes to the Cage to try to cash a personal check but the cashier notices
that the name on the ID doesn’t match the name on the check.
o If an ID looks like it’s been tampered with or just doesn’t look right, this is a
red flag for a fake ID
 Suspicious line of questioning: A customer asks an employee suspicious questions
such as “How many tickets can I cash out before you write my name down or before
you ask for my social security number”?
o Guests who ask questions regarding how to avoid our reporting thresholds is a
red flag for suspicious activity.
 The Unusual High Roller: A regular patron suddenly starts gambling with
significantly larger sums of money without any apparent change in their financial
situation. They seem unconcerned about their losses and exhibit nervous behavior
when asked about the source o their funds.
 The Sudden Teamwork: Two individuals who have never been seen together before
start playing at the same table, exchanging chips frequently. They seem overly
coordinated in their betting patterns, often placing large bets simultaneously or
taking turns winning and losing without any apparent strategy.
  The Suspicious Solo Player: An individual spends hours at the slot machines, making
minimal interaction with staff or other players. They cash out their winnings in small
increments, just below the reporting threshold, and seem reluctant to leave the
casino despite having won a substantial amount.
 The Cryptic Cryptocurrency Investor: A guest attempts to use cryptocurrency to buy
chips or cash out their winnings. They are evasive when asked about the source of
their digital funds and display a lack of understanding or unwillingness to comply
with the casino’s anti-money laundering procedures regarding cryptocurrency
transactions.
 Note: EVS employees (performing their normal duties) are more likely to spot signs
of money laundering. This is due to the fact that criminals (who are trying to evade
detection) are usually more on the lookout for security or eGames personnel
because they don’t think of EVS as someone who will be watching for illegal activity.

Let’s dive deeper into Money laundering:

 Many businesses take money under the table and then bring that illegally-obtained
(or unreported) cash to the casino.
 But did you know that if they do any transactions with that money, they’re
laundering it? That’s right!
CNE is committed to stamping out all forms of money laundering. Pot farms is a cash-heavy
business that tends to frequently launder money at our casinos. So, pay attention to any
guest who you believe could be involved in a marijuana-related business or any other
business that is cash-heavy such as poultry farms and nail salons.
Human trafficking: The buying and selling of a human being is also considered a form of
money laundering and employees that work in the casino industry have a unique vantage
point to identify potential human trafficking victims on our properties.

Real-life examples of human trafficking that would trigger a Suspicious Activity Report:
o A hotel front desk employee overhears a teenage boy soliciting himself to a
customer.
o Fact: Anyone selling sex under the age of 18 is legally a trafficking victim.
o A housekeeping employee notices a young woman being forced into a room and
overhears her being told to never answer the phone, answer the door or leave the
room.
o A customer tries to get a credit card advance on someone else’s card and they are
noticeably controlling the activities of that person; not allowing the card holder to
speak, show their ID or have anything to do with the transaction.
If you see any potential human trafficking, you are required to report it on a Suspicious
Remember, suspicious activity can be anything that seems suspicious… When in doubt, talk
to your Compliance Officer or file a suspicious activity report.
Keeping a keen lookout for suspicious activity means keeping your eyes and ears open to
what’s going on around you so you’ll be better equipped to identify red flags.
As you know, the Bank Secrecy Act dictates that casinos must
file Suspicious Activity Reports for any suspicious activity
involving transactions of $5,000 or more.
 But, as a reminder…
a. CNE employees should report ANY suspicious
activity (regardless of the amount) – and include
as much information as possible
i. There are several options for reporting
suspicious activity:
1. Preferred: Through CNB Connect,
using the digital SAR form
2. If CNB Connect is not available
use the manual form

b. And, regardless of your position, our regulatory operational procedure applies

to every single CNE employee, dictating that everybody has a responsibility
for Title 31, including non-gaming departments – no one is exempt.
Please contact your site Compliance Officer if you have any questions

Most Common Compliance-related Issues

Based on questions received by the Compliance Officer’s, exception reports and issues
found within the system… the most common compliance errors and issues are:
 Verifying ID’s
o Foreign, fake and unfamiliar
o Not being able to determine if an ID is an accepted form
 Guest’s EVERI Compliance Account
o Duplicate accounts
o Incomplete or inaccurate information
o Not updating the account with the most current ID
 MTL/Tracking Best Practices
o Selecting the correct transaction type in the system
o Leaving comments for uncommon transactions
o Recording the agent’s information
Let’s walk through them one-by-one:
 Verifying ID’s: The Compliance Officers agree that verifying ID’s is one of the most
common Compliance-related issues at our properties.
 Guest’s EVERI Compliance Account
o When searching for a patron, make sure there isn’t already an existing
account before we create another one.
 Note: If they have a Rewards Card, search the system with that
number because it is unique to each person
 You may need to try alternate spellings of the name
o Incomplete or inaccurate information on the guest’s EVERI Compliance
Account:
 We see this happening quite often with our regular guest’s accounts,
assumingly because gaming attendants have become familiar with their
guests over time; so, when they win a jackpot they tend to get in a
hurry to get them paid out, overlooking the importance of updating
their accounts.
 What should happen: When a guest hits a jackpot, the gaming
attendant should both visually verify their ID AND update their account
(while they have the opportunity) by scanning their most current ID
into the system while they’re processing the jackpot.
o Tip: Now would be a good time to also add the guest’s social
security card to their file (if they happen to have it with them)
because (in a perfect world) having this card on file potentially
saves future issues and it also documents their legal name on
file with the Social Security Administration.
o This is very important because all of the tracking that we
do is to determine if the guest’s total transactions exceed
the $10,000 threshold. And if so, they are to be reported
on a CTR.
o What you may not realize is… there’s nothing more important
than getting that paperwork right the first time because their
account information pulls directly onto the forms.
 So, if their information on file is incorrect:
We won’t have the correct information for
the Title 31 paperwork or for anything we
need to validate -for example:
o Subpoena requests
o SARs
o …or CTRs
 Plus, we’re then tasked with having to
watch for that guest until they come back in
to get the information we need.
In the meantime, Revenue Audit is tasked
with trying to obtain the correct
information so they can complete their IRS
forms:
o 1042S
o Prize Claim Forms
o W2Gs
 When W2G’s aren’t correct,
they get kicked back at the
end of the year due to an IRS
mismatch.
 Corporate Rev Audit will have
to obtain the correct
information from Loss
Prevention or other multiple
resources and then
regenerate a corrected tax
form to be sent to the guest
o So, please understand… this isn’t just a Compliance Department
issue when you fail to update a guest’s account in EVERI
o The bottom line: Regardless of the time it takes to properly fill
out the paperwork, it will protect the company and save your
coworkers hours of unnecessary work
 MTL/Tracking
o Many errors are being made when choosing the correct transaction type: The
correct transaction type must be selected.
 For example: A chip redemption may be coded as a ticket redemption
o Best practice: When you have an uncommon transaction, be sure to leave a
comment on the MTL so audit can have a better understanding of the
transaction
o If you have knowledge that an agent is working on the behalf of another
person, be sure to record the agent’s information on the MTL as well

Recordkeeping
You already play an important role in gathering information on a daily basis for tracking
guest activity that is recorded on the MTLs, NILs and CTRs.
The following simply serves as a reminder of the basic requirements:
 MTL (manual and electronic)
o A MTL should be completed for transaction(s) in currency involving either
cash in or cash out of more than $3,000 for a 24-hour gaming day.
 CTR (cash-in and/or cash-out transactions)
o To help address money laundering risks, the regulation states that:
 The information recorded on the CTR is complete and accurate for
all reportable transactions – either single or aggregated – that
exceed $10,000 in currency during a casino’s defined 24-hour
gaming day
 CTRs must be electronically filed within 15 days of the transaction
date.
o Note: A Suspicious Activity Report must be filed if:
 The guest’s activity has generated the filing of an incomplete CTR
and the guest has declined to produce the required information.
 If an incomplete CTR has been filed, it becomes CNE employee’s
responsibility to obtain the missing information so that an amended
CTR can be filed for the guest.
The guest is also banned from all CNE properties until the missing information can be
obtained.
 NIL
o Used to record all negotiable instruments
o This is the log utilized by the Cage to track incoming and outgoing checks
at or greater than $3,000.

What you may not realize…

… is how many organizations outside of CNE also depend on us to track that activity. The
reported information that we gather is maintained in a central repository and made
available to several law enforcement agencies and regulators:
 FinCEN - where we file CTRs and SARs
 Internal Revenue Service – tax filings and audits
 Department of Homeland Security (DHS)
 Immigration & Customs Enforcement (ICE)
 Federal Bureau of Investigations (FBI)
 Drug Enforcement Agency (DEA)
 The U.S. Attorney’s Office
Regulators are very serious about capturing this information and have been imposing hefty
fines for organizations that fail to follow reporting requirements.

Violations for non-compliance

 …could result in fines for CN, CNE and possibly individual employees depending on
their level of involvement of non-compliance

Location of all forms, documents and policy and procedures

All Title 31 forms and documents, IRS forms, as well as MICS and TICS and policy and
procedure… can be found on the CNB Connect Compliance Page.

Who to contact for questions

Please remember… Your property’s Compliance Officer is someone you can consult
with questions and reach out to for guidance.

 [Insert animated characters/with their respective locations]

The bottom line:

These best practices reflect CNE’s continuing efforts to lessen the risks of potential money
laundering and illegal activity connected with our properties.
Though perfection cannot be expected, our effective AML/BSA culture of compliance
program ensures that we continue to effectively combat money laundering or illicit
financing threats every single day.

Follow CNE processes and you’ll automatically be complying!

As an employee, you’ll find that you’re automatically in compliance if you follow CNEs
P&Ps, and processes… because the more you understand what we do and the ‘why’ behind
the processes... the more you’ll find that you are automatically in compliance!
 It’s important to remember that because ...when you comply with Title 31, you’re
not only protecting the company… you’re protecting yourself! So, please join us
in protecting the casino, the assets and the Cherokee Nation.