Extension without change of a currently approved collection
No
Regular
02/24/2021
Requested
Previously Approved
36 Months From Approved
02/28/2021
993
925
99,466
92,500
0
0
Section 352 of the USA PATRIOT Act added subsection (h) to 31 U.S.C. 5318 of the BSA. Section 352 mandates that financial institutions establish AML programs in order to guard against money laundering. Such AML programs must include, at a minimum, the following: (a) the development of internal policies, procedures, and controls, (b) the designation of a compliance officer, (c) an ongoing employee training program, and (d) an independent audit function to test programs. Pursuant to section 352, FinCEN issued a regulation requiring casinos to develop and implement written AML programs. Among other things, the casino AML program regulations require that a casino must implement procedures for obtaining and verifying customer identifying information, detecting the occurrence of transactions that must be reported as suspicious, and making and retaining specific records, including a copy of its written AML program.
The estimated total annual burden hours increased from 92,500 hours in 2017 to 99,466 hours in 2020. The estimated burden for casinos to implement and maintain an AML compliance program remained at approximately 100 hours per casino, with the addition of 5 minutes to store the written AML program and 5 minutes to produce the written program upon request. The increase in burden is due to a combination of the increase in burden of 10 minutes per casino, and an increase in the number of casinos from 925 in 2017 to 993 in 2020.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
1506-0051-Casinos AML Program Supporting Statement 2-24-2021 FINAL.docx
AML Program Requirements for Casinos (31 CFR 1021.210 and 31 CFR 1021.410(b)(10)