Anti-Money Laundering (AML)
Money laundering is a criminal activity designed to conceal the source of proceeds from illegal activities, or is conducted, or intended to be conducted, to hide or disguise funds or assets derived from illegal activities. Preventing money laundering is an essential part of global law enforcement efforts, as successful laundering efforts make it easier for criminals to receive and benefit from ill-gotten proceeds.
As one of the nation’s largest gaming companies, Boyd recognizes that casino gaming is a cash intensive business – and that we have a particular obligation to monitor for, and stop, attempts to launder money through our operations. Accordingly, Boyd seeks to promote and foster a companywide culture of anti-money laundering (AML) compliance through the following initiatives:
- Under AML policy, Boyd conducts our operations in accordance with federal law (Bank Secrecy Act, or BSA), as described in 31 CFR Chapter X and the American Gaming Association’s best practices.
- We provide regular AML training to appropriate gaming team members. The training is commensurate with each team member’s customer responsibilities and interactions, and specifically includes how to identify unusual financial transactions or suspicious activity, and how to prepare and file required reports when such activities are identified.
- We file Currency Transaction Reports with the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) whenever a customer conducts a currency transaction or transactions in excess of $10,000 in a single gaming day.
- When necessary, we will file a Suspicious Activity Report with FinCEN if we detect suspicious or potentially suspicious activities at our properties.
- We require our team members and properties to conduct proper Patron Due Diligence — knowing our guests and understanding the source of their funds.
- We conduct regular independent testing of AML procedures at our properties to ensure proper compliance.
- When necessary, we will stop the play of any customer who is suspected of engaging (or attempting to engage) in money laundering activity.
What We Look For With AML
Some examples of suspicious behavior might include:
- Buying into a table game with large amounts of cash, playing for a short time or having unusually low wagering activity, then attempting to cash out at the cashier’s cage.
- Leaving the casino with a large quantity of chips, and not returning within a reasonable timeframe to redeem them (also known as “chip walking”).
- Inserting large quantities of small bills into gaming devices, not putting the funds at risk through valid play, then cashing out the funds for larger denomination bills (also known as “bill stuffing”).
- Making casino-wagering account deposits and withdrawals in large amounts without commensurate play to support the activity.
- Using the casino’s financial services (i.e., credit, check cashing, cash advances) without valid play to support the activity.
- Individually, or through the use of agents, intentionally breaking up large cash transactions into smaller amounts that fall at or below the $10,000 Currency Transaction Report threshold (also known as “structuring”).
- Refusing to proceed with a transaction after being advised that a Currency Transaction Report must be filed.
- Refusing to provide identification, or providing insufficient or conflicting identification information.
For more information on our Anti-Money Laundering Policy, click here.