Anne Marie Minogue, Senior Director Global Investigations and Compliance for independent consultancy Navigant, talks about the firm’s interest in sports betting and how it can help operators navigate what can often be choppy regulatory waters.
SBC Americas: Can you give us a brief outline of what Navigant does and who would be its typical clients?
Anne Marie Minogue: Navigant is an independent consulting firm with a stellar reputation as a leader in the US and global markets in developing, enhancing, implementing, and assessing Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and sanctions compliance and risk management programs for financial institutions, casinos, and the regulators that oversee them. Our team is comprised of former regulators, compliance officers, bankers, prosecutors, law enforcement officials, software developers, and IT specialists. Our years of experience, subject matter expertise, and practical knowledge enable us to deliver sustainable AML and sanctions compliance solutions to the financial services industry worldwide.
Navigant services a diverse client base, including banks, broker-dealers, investment advisers, hedge funds, casinos, and money service businesses internationally. In addition to extensive experience working with financial institutions and regulatory agencies, Navigant has assisted casino and gaming institutions navigate complex regulatory challenges and strengthen their BSA/AML compliance programs. We add value to both developing and established gaming institutions by building and implementing cost-effective solutions to safeguard against fraud, corruption and abuse.
SBC Americas: What is Navigant’s interest in sports betting and how does its offer tie in with the sports betting sector?
Anne Marie Minogue: Any institution that accepts and sends wire transfers or other electronic payments, extends credit, allows the deposit of funds, or pays out in cash or check, is classified as a financial institution under the Bank Secrecy Act. As more states legalize brick-and-mortar and online sports wagering, the gaming industry will become increasingly subject to state and federal BSA/AML policy.
That is where we come in. Navigant partners with organizations whose compliance obligations, regulatory exposure, or investigative responsibilities are impacted by federal legislation, such as the repeal of PASPA. Navigant is the one-stop shop for all sectors of the industry because of our ability to apply deep and extensive regulatory and financial crime expertise, create and assess bespoke compliance programs, investigate fraud and suspicious activity, implement and manage advanced data analytics, and manage requests and relationships from regulators and enforcement agencies.
For sportsbook operators and gaming establishments in particular, developing and maintaining compliance program elements such as whistle blowing, risk assessment, program governance, patron identification, transaction monitoring, and investigative capability are crucial to an effective control environment. The risks of noncompliance include significant monetary penalties that could be a show-stopper for any up and coming sportsbook. Navigant can minimize this risk by providing its clients with the independence and expertise they require.
SBC Americas: What did you learn from your attendance at the Betting on Sports America conference?
Anne Marie Minogue: Our discussions with attendees, exhibitors and panelists made it clear that the industry as a whole is optimistic about state level legalization of sports wagering in the United States. It was apparent that while industry operators are mindful of compliance when it comes to the implications of the Wire Act, licensing requirements, and combating the black market, financial crime compliance and BSA/AML program requirements, however, are not at the forefront of the discussion. Navigant recognizes that as players in the sports wagering industry evolve and expand their operations, they will need guidance on how to build and implement solutions to safeguard against fraud, corruption, and abuse. Navigant is excited to partner with industry operators to reduce their financial crime risk and ensure that their legitimate operations are not co-opted by criminal infiltrators.