In the past 12 months, anti-money laundering compliance has come to the forefront in the gaming industry in Nevada and worldwide. Against that backdrop, the annual BSA/AM Gaming Conference kicks off Monday morning in Las Vegas.
The conference will feature some of the most influential figures in financial-crime enforcement and policy. It comes as the casino industry has faced criticism that it isn’t doing enough to address the problem of money laundering.
Last year’s event hosted more than 550 attendees from 39 states, three foreign countries, dozens of tribes, and over 160 gaming entities. The conference is closed to the press.
Among the speakers at this year’s event, which runs through Thursday at Planet Hollywood, are Guy Ficco, chief of IRS-Criminal Investigation, who will talk about the importance of Suspicious Activity Reports in federal investigations. He will also highlight CI’s role in recent high-profile financial-crime cases.
Carole House, former Director for Cybersecurity and Secure Digital Innovation at the White House National Security Council and senior advisor at the Financial Crimes Enforcement Network (FinCEN), the bureau of the U.S. Treasury responsible for enforcing the Bank Secrecy Act, will deliver a keynote exploring the intersection of AML compliance, national security, and emerging technology.
Former directors of FinCEN will share perspectives on how BSA policy has evolved over time and what the future holds for AML regulation for the gaming sector. Several other high-level government officials — state and federal, civil, regulatory, and criminal — will also speak.
The conference will focus on in-depth studies of recent enforcement actions, emerging issues involving know-your-customer and source of funds, a presentation regarding data analysis and player risks, and new unregulated gaming models.
“Our goal has always been to bring together the best minds from government and industry to share real-world solutions,” said James Dowling, co-founder of the BSA-AML Compliance Group and president and managing director of the Dowling Advisory Group. “With keynote speakers like Guy Ficco and Carole House and the participation of former FinCEN Directors, this year’s event will be our most impactful yet.”
Mike Dreitzer, the new chairman of the Nevada Gaming Control Board, will convene the conference Tuesday morning. Gaming Control Board member George Assad will give a presentation Tuesday afternoon about the Board’s penalizing Wynn Resorts, MGM Resorts International and Resorts World Las Vegas over lack of AML compliance. This session will offer insights into regulatory priorities and enforcement trends.
“I think it’s an excellent conference with experienced attendees and speakers and a great opportunity to educate and exchange views on a very important topic,” Dreitzer said. “In many ways, it’s more relevant than ever,” because of the importance of AML and any opportunity to bring together expertise is critical for the industry.
The conference will cover artificial intelligence and how that has brought new opportunities for anti-money laundering compliance, but also new risks. A panel will unpack the new challenges that “deepfakes,” videos in which people’s faces or bodies have been digitally altered to spread misinformation, pose new challenges to compliance efforts and what law enforcement and industry have done to mitigate those risks.
Cryptocurrencies and other digital assets are also offer a host of new opportunities and risks, with illicit actors attempting to use them for money laundering, sanctions evasion, and other unlawful activities. A panel will provide an overview of the crypto landscape and the evolving intersection between crypto and gaming.
The conference will also address the hottest topics in gaming: sweepstakes, skill games, and event-based contracts. Proliferating nationwide, they often operate outside traditional casino regulation. Attendees will hear from regulators about enforcement challenges, market impacts, and what these trends could mean for the future of regulated gaming.
Assad will give an overview of the three cases in which millions in fines were levied against Resorts World, MGM, and Wynn and provide guidance to the compliance people in attendance on how to avoid money-laundering pitfalls.
“One theme is separating compliance people from marketing people, so they can’t be influenced,” Assad said. “The other one is, hopefully, that through all the enforcement actions we’ve undertaken, we’ll change the history and culture of what’s happened in Las Vegas for the last 40 years or so with respect the casinos allowing anybody and everybody to wager, without doing sufficient know-your-customer background checks and verifying sources of funds.”
When asked why so many AML cases have made headlines over the past year, Assad said enforcement had previously been lax at the state and federal level.
“That’s changing, especially in Nevada. We want to maintain law and order with respect to money laundering, because of terrorism. We want banking institutions and casinos to help the federal government follow the source of money with regards to terrorist activity. In the past, it wasn’t a priority for the feds. They were focused more on terrorism and not so much on straight-up money laundering by gamblers. We’re trying to change that culture, so the casinos pay more attention and we don’t have federal intervention. Whenever you have any type of federal intervention, (a federal gaming tax) will pay the tab for the government’s work in that area.”
