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CDD & Preventing Fraud

by | Aug 7, 2023

How Smart Casino Managers are Preventing Fraud and Protecting Assets Leveraging CDD Information Governance

Customer Due Diligence (CDD) is the process of collecting and verifying information about a customer during new customer onboarding. This CDD collection process includes the customer’s name, address, and other personal data, all of which are covered under Privacy Laws in the EU and United States.

Casinos, in particular, must carry out CDD when establishing a relationship – and smart general managers know how to leverage the right tools to implement CDD rules in a transparent, reportable, quick turnaround process that onboards potential big rollers onto the gaming floor as quickly as possible.

How the WIS CDD Solution Works

  • At the cashier counter, the casino customer scans their ID presented on a purpose-built scanner, that accepts either passport or an identification card, like a driver’s license.

While the greeter engages with the customer, the WIS CDD solution extracts the information off the ID using intelligent document recognition and SmartLearning, validates the information against existing multiple databases including:

  • USPS
  • State DMVs
    • Facial recognition
    • Signature verification
  • Fraud Alert Portals
  • Countries’ Passport Portals
  • Internal CRM, ECM or EDM
  • Any casino-accessible web-based portal
  • This search notifies the greeter and/or Cage Operations if there are any issues before an account is set up or credit is extended and preserves the transaction in the casino’s ECM or EDM for disposition once the information has reached its retention period.

The entire CDD process is logged for further actions, including compliance reporting.  Now, the gaming organization has documentation showing that the casino performed due diligence.

A complicating factor for casinos is the multitude of data privacy laws taking effect during 2023 in California, Virginia, Colorado, Utah, and Connecticut, specifically: California Privacy Rights Act, effective January 1, 2023, Virginia Consumer Data Protection Act, effective January 1, 2023, Colorado Privacy Act, effective July 1, 2023, Connecticut Data Privacy Act, effective July 1, 2023.

Casinos whose customers reside in one of those states need to be prepared to process requests to be forgotten.  In addition, California’s laws cover employees so casinos need to be prepared to remove employee data from their systems as well.

A tool to document the business needs for all the records gathered in a casino, from the previously mentioned customer due diligence records to benefit payouts to floor surveillance footage is a records retention schedule.

If your records retention schedule hasn’t been updated in the past five years, it’s time to take a look so that the records you need to prove financial management and CDD compliance are kept for as long as the relevant laws require.  Be ahead of requests by having a process in place.  This ensures that if you do receive a request to be forgotten, you know which records you need to keep to maintain compliance and get rid of the ROT: Redundant, Obsolete and Transitory.

Written by Cheryl Young

Cheryl Young (Senior Project Manager, CSM, CSPO, IGP, CTT+, ermM, ecmP) has been active in the records and information management field for over 30 years as a business process consultant, trainer, records manager, information analyst, contracts manager and project manager with specific expertise in RIM projects trusted systems and Lean process analysis. Cheryl is a frequent speaker with AIIM and ARMA.



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