Knowing Your Employees: Understanding Staff Risk in Gaming Venues

Staff can be both a critical line of defence and a source of risk in managing financial crime risks.

Staff risks should be considered as part of your AML/CTF Program, especially where you are a reporting entity with gaming machines.

This includes:

• Having policies to reduce risk in your hiring and on-boarding processes (for example, criminal history checks and reference checks);
• Ensuring AML/CTF and fraud awareness is part of your staff induction training;
• Having processes for training staff in transaction monitoring and internal reporting requirements; and
• Implementing ongoing controls to identify risks posed by staff behaviour, including monitoring suspicious transactions and movement of funds.

Think about what access staff have – are they:

• Handling large amounts of cash?
• Involved in paying out winnings?
• Accessing customer account details?
• Managing ticket-in-ticket-out (TITO) or cashless systems?
• Setting or overriding machine configurations?
• Managing surveillance and CCTV footage?
• Able to edit or delete electronic records?

What measures do you have in place to detect:

• Conflicts of interest (e.g., staff playing on their own shift)?
• Collusion (e.g., staff assisting customers in avoiding detection)?
• Theft, fraud, or abuse of internal systems?

It is also important that your transaction monitoring program and controls aren’t only targeted at external customer behaviour. Consider how your systems could pick up unusual staff behaviour, including:

• After-hours access or activity;
• Repeated adjustments to machine settings;
• Unusual ticket or cash movement patterns; and
• Attempts to delete or edit data.

Lastly, think about the culture you set at your venue. Is staff misconduct taken seriously? Are concerns escalated and investigated promptly? What tone is set by management and owners?

Staff are your greatest asset – make sure they are also your greatest safeguard.