Anti-Money Laundering Compliance

AGA will continue to be a leading advocate for the industry by demonstrating gaming’s commitment to a culture of compliance. AGA will seize opportunities to lead productive discussions with the U.S. Department of Treasury’s Financial Crimes Enforcement Network and other stakeholders to ensure the gaming industry is fairly regulated.

Best Practices for Anti-Money Laundering (AML) Compliance

The modern casino is an entertainment venue that offers its patrons highly regulated gaming, often combined with hotels, multiple dining options and live entertainment. To facilitate gaming activity, casinos ordinarily provide some financial services to their patrons. Although the vast majority of patrons visit casinos for entertainment, leisure and diversion, those engaged in illegal activity may attempt to use the casino’s financial services to conceal or transfer illicit wealth.

To discourage such behavior and safeguard the integrity of the casino industry and the U.S. financial system, casino companies have developed effective risk-based programs in an effort to ensure compliance with the legal requirements of the federal Bank Secrecy Act (BSA) and associated anti-money laundering (AML) statutes and regulations.

The goal of this document is to provide a resource for industry and law enforcement to help guide their efforts to protect the gaming industry and the broader financial system from money launderers and others involved in illegal activity.

AGA's Best Practices for AML Compliance

AML Effectiveness and BSA Modernization

The gaming industry is dynamic and seeks an AML regime that is responsive to new trends, technologies, and threats. That is why AGA’s AML/BSA Working Group has responded to requests from the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) to provide recommendations on how the country’s AML regime could be more effective and how to update the BSA. The industry’s recommendations focused on updating regulations to keep up with technological advances, increase coordination with law enforcement, and gaming-specific provisions to help support our culture of compliance.

Several of the policies that AGA has advocated for were included in the Anti Money Laundering Act of 2020, the first significant revision of the BSA since 2001. We will continue to work with Congress and Treasury officials to strengthen the security of our financial systems.

Mar 2022 Letter to FinCEN re: SARs Pilot Program
View Letter
Feb 2022 Letter to FinCEN re: BSA Regulations
View Letter
Nov 2020 Letter to FinCEN re: AML Program Effectiveness
View Letter