• advocacy

    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 and leisure, those engaged in illegal activity may attempt to use the casino’s financial services to conceal or transfer illicit wealth through cash or digital payments. Online gaming has many of the same money laundering and illicit finance risks associated with in-person casino gaming, as well as additional challenges.

    To discourage such behavior and safeguard the integrity of the gaming 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), Anti-Money Laundering Act (AML) and other AML statutes and regulations. As a result, the gaming industry has emerged as a respected leader in AML compliance across the country.

    Updated in 2022, the goal of this document—reviewed and revised by the country’s top compliance professionals—is to provide a resource for the gaming industry and law enforcement to help guide their efforts to protect the 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