Why CGCS? Creating a culture of gaming compliance through a uniform approach to role training
There have been a number of high profile scandals in recent years involving the casino gaming industry. Those in Australia and Canada, to name just two, centered around compliance failures by casino operators when it came to their operations.
The number one element of a compliance program is the “tone from the top” - the C-Suite’s commitment to compliance - that sets the tone for what is, and what isn’t, acceptable behavior. In the case of Crown Resorts in Australia, this led to CEOs resignation.
It should be noted that the casino gaming environment is unlike any other.
Unlike financial institutions whose AML and Regulatory Compliance functions are often consolidated within back office non-customer facing functions, there are a greater number of casino employees - at a wide range of levels and positions - involved in preventing and detecting suspicious activity and crime.
Consider;
Cage staff accepting funds and handling requests for disbursement
Table dealers interacting with customers and handling table buy-ins
Floor security personnel observing customer(s) behavior
Surveillance staff observing customer(s) behavior through the “eye in the sky” and monitoring automatic activity alerts
A casino’s own AML or Financial Crime Unit monitoring customer transactions and activity
Each of these roles has the potential to identify suspicious activity and be the author of a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR). But it should be noted that each role is only one element of a wider casino compliance ecosystem. A siloed approach to casino compliance is doomed to failure and missed opportunity - potentially leaving risky activity “on the table”.
It is important that AML training is tailored to each role - the Board of Directors requires different AML training that the AML Unit for example - but there is also a need for training to demonstrate the interconnected nature of each role. That why the Certified Gaming Compliance Specialist was designed to provide knowledge and awareness of each role, and provide casino staff with an understanding of where they fit within the casino ecosystem.
Within the Certified Gaming Compliance Specialist curriculum, modules provide a comprehensive insight into the different roles with a casino compliance remit. For example,
Modules 14-16: Anti-Money Laundering
Modules 24-33: Fraud
Modules 34-39: Corruption
Module 52: Internal Audit
Module 56: Security and Surveillance
In addition to providing a strong knowledge input on different roles with the casino environment, and in order to create a culture of compliance, there is a strong focus on Ethics and Leadership:
Module 1: What is Leadership?
Module 2: Different leadership styles
Module 3: How to Become a Leader
Module 4: Leading Teams and Groups
Module 5: Motivating Employees and Team Members
Module 6: Leadership style
Module 7: What is Management?
Module 8: The attributes of a leader
Module 9: The Foundations and Philosophy of Ethical Behavior
Module 10: Codes of Conduct and Professionalism
Module 11: Internal accountability
Module 12: External accountability
Module 13: Ethical leadership
It is perhaps not surprising that a number of casino operators are looking to the Certified Gaming Compliance Specialist to become the enterprise-wide training for their casino staff.
The creation of the Certified Gaming Compliance Specialist represents an industry first - there is no other certification specifically designed for the needs of the casino gaming industry.