AML Compliance Statement

BANK SECRECY ACT AND ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM

Morongo Casino Resort and Spa (MCRS or “we” or “our”) has developed a strict Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) for our casino, hotel, resort, and spa in an effort to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering. This includes, but is not limited to:

• Establishing robust internal policies, procedures and controls that combat any attempted use of MCRS for illicit purposes and that are designed to ensure our patrons’ protections under consumer protection laws;
• Complying with the applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”);
• Filing Suspicious Activity Reports (“SARs”);
• Filing Currency Transaction Reports (“CTRs”);
• Maintaining comprehensive records of credit/debit card advances, wire transfers, marker activity, and other transactions;
• Employing an AML Officer who is responsible for the implementation and oversight of our BSA/AML Program;
• Executing Know Your Customer (“KYC”) procedures on all patrons;
• Performing regular, independent audits of our BSA/AML Program;
• Implementing a formal and ongoing compliance training program for all new and existing gaming employees.

POLICIES AND PROCEDURES

Our BSA/AML Program is regularly reviewed and, if necessary, revised in an effort to comply with applicable rules, regulations, policies, and best practices. We are regulated by the Internal Revenue Service and our BSA/AML Program is subject to its examinations and approval.

INTERNAL CONTROLS

We have developed robust internal policies, procedures, and controls designed to comply with applicable BSA/AML laws and regulations, some of which are outlined here on this page including, but not limited to, our Customer Identification Program (“CIP”), the filing of SARs and CTRs, and other reporting requirements and audits.

TRAINING

All of our employees and officers receive ongoing broad-based BSA/AML training, as well as position-specific training. They must repeat this training at least once every twelve (12) months to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. New employees receive training within five (5) days of their start date. All documentation related to compliance training including materials, tests, results, attendance and date are maintained. In addition, our compliance training program is updated as necessary to reflect current laws and regulations.

AML OFFICER

Our AML Officer (AMLO) is responsible for developing and enforcing the policies and procedures of our BSA/AML Program. Our AMLO is required to report any violations of our BSA/AML Program directly to our Credit/AML Committee. In addition, our AMLO is responsible for recording and filing SARs, CTRs and performing a BSA/AML Program audit at least annually.

CUSTOMER IDENTIFICATION

Our Customer Identity Program (“CIP”) is an important part of our BSA/AML Program, and helps us detect suspicious activity in a timely manner and prevent fraud.

FINANCIAL TRANSACTIONS BETWEEN PATRONS AND MCRS

In order to conduct cash advance, marker, or wire transactions through MCRS, your identity must be verified, authenticated, and checked against government watchlists, including the Office of Foreign Assets Control (“OFAC”). Failure to complete any of these steps will result in your inability to transact with MCRS, and potentially a ban on all gaming activity at MCRS.

Prior to extending credit, issuing a marker, or conducting any other significant financial transaction for a patron, we attempt to collect, verify, and authenticate the following information:

• Full legal name;
• Social Security Number (“SSN”) or any comparable identification number issued by government;
• Date of birth (“DOB”);
• Proof of identity (e.g., driver’s license, passport, or other government-issued ID);
• Home address (not a mailing address or P.O. Box); and
• Additional information or documentation at the discretion of our Compliance Team.

SUSPICIOUS ACTIVITY / CURRENCY TRANSACTION REPORTS

We file Suspicious Activity Reports (SARs) if we know, suspect, or have reason to suspect suspicious activities have occurred at MCRS. A suspicious transaction is often one that is inconsistent with a patron’s known and legitimate gaming activities or personal means. We leverage our Compliance Department, which performs transaction monitoring to help identify unusual patterns of patron activity. Our AMLO reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR.
In addition, all currency transactions totaling $10,000.01 or more during a single gaming day are reported to FinCEN via a CTR filing.

Our AMLO maintains records and supporting documentation of all SARs and CTRs that have been filed.

REPORTING REQUIREMENTS

All records are retained for five (5) years and are readily available upon official request by an applicable examiner, regulator, or law enforcement agency.

BSA/AML PROGRAM AUDIT

Our AMLO oversees the performance of an independent test of our BSA/AML Program at least annually. The AMLO is not responsible for the independent test, and the AMLO’s performance is a subject of the test. Results are sent directly to the Credit/AML Committee.