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 others 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.

AML Effectiveness

In November of 2020, the AGA AML/BSA Working Group responded to a request 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. 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 AGA 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.

Letter to FinCEN's Policy Division
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FATF Recognizes Gaming’s Commitment to Compliance

The influential international body that grades countries' efforts to prevent money laundering recognized casino gaming companies' significant investment in anti-money laundering (AML) efforts, reporting that the industry "has good understanding of risks and obligations," puts in place "mitigating measures above the requirements" of the Bank Secrecy Act (BSA) and has shown "an increased focus" on raising awareness and improving compliance."

The Financial Action Task Force (FATF) released its mutual evaluation report for the United States in December 2016. FATF releases such reports once every ten years, and its 2016 report found, “the gaming industry has taken significant steps to comply with AML/CFT [combatting the financing of terrorism] requirements…casinos have not only increased their compliance spending but have also put in place mitigating measures above the requirements of the BSA based on their risk.”

In advance of the FATF evaluation, gaming companies took aggressive action to improve AML compliance, and the American Gaming Association (AGA) demonstrated these improvements through a groundbreaking report earlier this year. In 2014, AGA also released a first-ever Best Practices for AML Compliance, which it updates annually.

FATF praised both reports by name in its evaluation. AGA “works to assist the sector by putting out useful best practices guidance,” and the recent study on Investing in America’s Financial Security: Casinos’ Commitment to Anti-Money Laundering Compliance commissioned by the AGA provides a good picture of the understanding of the casino sector and the mitigating measures they have put in place.”

FATF, in 2006, recommended the industry take a number of steps to increase its customer identification procedures, reporting of suspicious transactions while further regulating, supervising, and monitoring anti-money laundering operations. The 2016 FATF report recognizes the industry’s enhancements, highlighting that the gaming industry has taken significant steps to comply with AML/CFT requirements and to prevent potential money laundering and terrorist financing. Further, the report acknowledges that in some areas, industry practices exceed federal BSA requirements.

The FATF mutual evaluation process results in comprehensive written reports that are used by governments and the private sector to underscore the money laundering and terrorist financing risks posed by countries and the financial sectors within them. When making gaming licensing decisions, foreign regulators may use these reports to consider whether an applicant comes from a jurisdiction with strong oversight and controls to combat illicit finance. Similarly, financial institutions use these reviews as part of their calculus with respect to financing and other critical financial decisions.

FATF is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction. The FATF Recommendations are recognized as the global AML and counter-terrorist financing standard.

Anti-Money Laundering Research


Ahead of a major international evaluation of the United States’ system for preventing criminal abuse of the financial system (FATF Mutual Evaluation 2016), the American Gaming Association (AGA) released the most comprehensive examination ever conducted of the U.S. casino gaming industry’s compliance with anti-money laundering (AML) compliance.

The report was commissioned by AGA and facilitated by Big Four accounting and consulting firm, Ernst & Young LLP.

The report marks the latest example of casino gaming companies aggressively seeking to demonstrate the industry’s commitment to AML compliance.

Investing in America's Financial Security
Casinos' Commitment to Anti-money Laundering Compliance
View Report
Gaming Industry Standard
New Report: U.S. Gaming Industry Setting High Standard for Anti-Money Laundering Compliance
View Release

Casinos a Bright Spot in Key Report Grading U.S. Anti-Money Laundering Measures

The influential international body that grades countries’ efforts to prevent money laundering today recognized casino gaming companies’ significant investment in anti-money laundering (AML) efforts, reporting that the industry “has a good understanding of risks and obligations,” puts in place “mitigating measures above the requirements” of the Bank Secrecy Act (BSA) and has shown “an increased focus on raising awareness and improving compliance.”

Grading U.S. AML Measures
View release