Our industry’s commitment to a culture of compliance is stronger than ever. One year after issuing the first-ever comprehensive set of Anti-Money Laundering (AML) Best Practices, AGA today released updates that include:
- Enhanced emphasis on instilling a strong culture of compliance;
- More robust assessment of money laundering risks;
- Incorporation of key conclusions from the U.S. Treasury Department; and
- Improved employee training on the latest AML updates.
Increasing Industry’s Role in Money-Laundering Prevention
Our updated Best Practices ensure that casinos of all sizes are protecting themselves 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.
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.
Further updates to the Best Practices include:
- 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.
We will continue to bolster these Best Practices to adapt to evolving threats and incorporate guidance from FinCEN and other regulators who share our goal of preventing money laundering and any other illicit activity from occurring at gaming properties.
If you have feedback or questions regarding these Best Practices, please contact Elizabeth Cronan, senior director of gaming policy. Thank you for your continued engagement on this and other important issues affecting our industry.
