The Division of Compliance has the responsibility to ensure the integrity of casino gaming operations and to maintain a compliant environment by detecting and preventing regulatory issues following the CCC Regulations, MICS, CNMI laws, and applicable federal laws.
The Compliance Division oversees Saipan’s exclusive casino licensee’s operations to ensure compliance with P.L 18-56, P.L. 19-24, Casino Regulations, Minimum Internal Control Standards (MICS), Casino License Agreement, and other CNMI and applicable Federal Laws and Regulations.
The Division monitors IPI’s operational compliance with the following:
- Gaming Operations Compliance
- Technical Compliance
- Bank Secrecy Act/Title 31 Anti-Money Laundering Compliance
Gaming Operations Compliance
The Compliance Division is assigned the responsibility of reviewing, investigating, and making recommendations for approval or denial to the Executive Director in all matters related to changes in gaming operations of the Casino Cage, Table Games, Electronic Gaming Machines (EGM), and Surveillance & Security.
All of the table games previously offered at the Best Sunshine Live Training Facility (BSL) and currently offered at the Imperial Pacific Resort & Hotel - Saipan (IPR) have been reviewed and investigated by the Compliance Division before going-live on the casino floor. The Compliance Division continues to diligently monitor and regulate the said tables and respective accessories, including (but not limited to) the following:
- • Playing cards, dice, and chips & plaques.
- • New table games rules and regulations
- • Marketing promotions, tournaments, and events.
Within the compliance reviews of EGMs, the Compliance Division perform detailed reviews of all EGM game concepts, rules of play, return-to-player ratio, peripherals, performance metrics/statistics, and all gaming software & firmware.
The Compliance Division continues to diligently monitor and regulate EGMs through the following:
- • Review of certificates of all gaming laboratory tested and approved hardware, software, and firmware. The primary goal of EGM regulatory compliance is to ensure all gaming devices are fair, secure, and capable of accurate operation and audit.
- • Tracking of all movements, purchases, destruction, and sale of these devices, ensuring that only the authorized parties are involved in these processes.
- • Frequent communications with EGM manufacturers and gaming laboratories to ensure that all of the EGMs are in compliance and are up-to-date on the latest technologies in electronic gaming.
- • Ensure EGMs are in conformity with Gaming Laboratory International (GLI) standards.
Together with the IT Unit, the Compliance Division also monitors the Casino Management System (CMS) for integrity and interoperability with the Table Games, EGMs, Casino Cage, Marketing, and Accounting system by means of:
- • Review of all software and firmware versions, upgrades and bug fixes.
- • Review other IT devices such as NRT machine (kiosk for slot ticket redemption), NICE Actimize solution (Anti-Money Laundering solution), NEWave (Title 31 solution), and Dallmeier System (Surveillance monitoring system).
- • Monitoring and regulating all access (including remote access) and maintenance of all servers.
Bank Secrecy Act/Title 31 Anti-Money Laundering Compliance
The CCC requires the casino licensee and junket operator licensees to comply with all CNMI and applicable US federal laws, with an emphasis on Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations promulgated by Financial Crimes Enforcement Network (FinCEN). The Compliance Division, together with other CCC Divisions, review and monitor the implementation of AML/CTF program developed by the casino licensee and junket operator licensees. The Compliance Division does this by examining the following reports and documents:
- • Written Internal Controls, Policies, and Procedures
- • Compliance Committee Meeting Reports
- • Know Your Customer/Customer Due Diligence
- • Currency Transaction Reports
- • Suspicious Activity Reports
- • Employee AML/CTF Training Program
- • Independent Test Review