Dear Gaming Colleague:
The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently released guidance for casinos’ sports book operations. As Reuters reported, while the American Gaming Association (AGA) welcomes continued insight, we ask FinCEN for its support along with other law enforcement agencies to join our current efforts to root out illegal gaming.
As the Wall Street Journal reported, the AGA welcomes ongoing dialogue with FinCEN to inform our industry’s risk-based approach to protect both our casinos and the U.S. financial system from attempts to launder money. Evidence of our partnership, FinCEN gave the AGA advance notice of this guidance, and wrote: “FinCEN appreciates the efforts of your organization to help maintain industry focus on the importance of the BSA, and the effort that the American Gaming Association has put into the recent release of a best practices document.” In concert with discussion of sports book operations, we request consideration of the money laundering risks in the vast, illegal sports betting market.
Overview of Sports Book Operations
While limited sports betting is allowed in Delaware, Montana and Oregon, Nevada is the only state permitted full sports betting. In 2013, $3.62 billion was wagered through sports books in Nevada. Yet, according to the National Gambling Impact Study Commission report released in 1999, the illegal U.S. market is estimated to be $80-$380 billion annually, which in more than a decade have undoubtedly increased.
Legal sports betting operations uphold robust anti-money laundering (AML) protocols as part of casinos’ risk-based approach to compliance. The AGA recently released Best Practices for AML Compliance after more than a year of work to identify and outline industry guidelines, developed in coordination with FinCEN.
Focus on Illegal Market
Historically, casino gaming companies have aided law enforcement with combatting illegal gaming operations. It’s partnerships such as these that the AGA looks to bolster and expand as we begin to examine the illegal sports betting market. We will keep you informed of progress as these partnerships develop.
Sincerely,
Geoff Freeman
President and CEO
