Casino industry unveils new best practices for anti-money laundering compliance

The Best Practices guide the efforts of casinos to protect the U.S. financial system and America’s national security from money laundering and other forms of illicit finance. The landmark first version of the document was developed in coordination with the Financial Crimes Enforcement Network (FinCEN) and with compliance representatives from a broad array of AGA member companies.

“Our industry’s commitment to a culture of compliance is stronger than ever, and our updated Best Practices ensure that casinos of all sizes are protecting themselves and America’s national security,” said Geoff Freeman, president and CEO of the AGA. “We will continue to bolster these Best Practices, adapt to evolving threats and incorporate guidance from FinCEN and other regulators who share our goal of preventing illicit activity from occurring at gaming  properties.”
 
Among the updates to the Best Practices are:

Enhanced emphasis throughout the entirety of the updated Best Practices on the importance of instilling a strong culture of compliance, aligned with FinCEN’s guidance; 

More targeted and extensive assessment of money laundering risks, focused on the various aspects of a casino, including: gaming floor activity; race and sports book activity; cage focused activity and information from the back of the house;

Incorporation of key conclusions regarding potential risks in casinos from the Treasury’s National Money Laundering Risk Assessment; and Employee training section enhancements to ensure that employees receive timely updates on developments in laws, regulations and Government issued guidance.

Casino companies have developed robust risk-based programs that promote compliance with the requirements of the federal Bank Secrecy Act (BSA) and associated AML regulations to discourage illicit behavior and safeguard the integrity of the casino industry. Risk-based compliance efforts are essential to the casino industry’s effective implementation of AML controls.