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Meaningful Regulation

AGA proactively engages with regulators

The Financial Crimes Enforcement Network (FinCEN), within the U.S. Department of Treasury, is tasked with safeguarding our nation’s financial system from illicit funds and money laundering. Over the last year, the agency has increased its engagement with the gaming industry.

At G2E 2013, FinCEN Director Jennifer Shasky Calvery highlighted the important role casinos play in combating money laundering. Our industry embraces this commitment to federal anti-money laundering (AML) compliance along with the hundreds of other regulations and statutes across all levels of federal, state and local governments, which we follow.

The AGA’s member-led Bank Secrecy Act (BSA) working group has engaged more closely with FinCEN on federal AML compliance, development of best practices for the gaming industry, and reiterating our industry’s commitment to a culture of compliance in Washington.

Establishing the foundation of this more frequent engagement, the AGA has outlined several principles with respect to engaging with FinCEN. We’ve aimed to:

• Proactively communicate with FinCEN;
• Continue to work cooperatively and transparently with FinCEN;
• Represent the industry and illustrate commercial casino operators’ alignment with FinCEN’s expectations; and,
• Highlight the gaming industry’s significant investment and commitment to AML compliance.

Through the AGA member-led working group, the AGA holds steadfast commitment to broadening FinCEN’s understanding of the gaming industry.

Increased Cooperation with FinCEN

Some of the recent progress toward building a more cooperative relationship with FinCEN includes:

• Establishment of a day-to-day point of contact within FinCEN and the gaming industry;
• Frequent face-to-face meetings in Washington, D.C. on emerging AML issues;
• Insightful perspective from FinCEN on best practices for the gaming industry; and,
• Ongoing dialogue to clarify procedures to align understanding and more clearly affirm our industry’s commitment to a culture of compliance.

While we are pleased with this incremental progress, we believe there are additional opportunities to partner with FinCEN.

Ongoing Progress for Partnership

Our industry prides itself on its innovative security and surveillance technology. Gaming’s sophisticated systems protect the safety of our customers and the communities in which we are located—as well as our business interests. Through federal investment, FinCEN too has leading technology to analyze its financial intelligence.

With closer collaboration, our industry’s technical and financial expertise could more effectively assist FinCEN. However, true partnerships are a two-way street. We too believe that authorization to glean insight on Suspicious Activity Reports (SARs) across gaming properties that are owned by the same parent company would greatly aid our efforts to narrow our unified focus on those who present the highest threat and better protect the majority of our customers, our business and our nation’s financial institutions from crime.

This approach to protection through partnership reminds me of the progress we were able to achieve during my tenure at the U.S. Travel Association. Post 9/11, the United States’ aviation system and the Transportation Security Administration (TSA) experienced major changes to better protect our nation’s security. Unfortunately, the new systems suffered from major inefficiencies, and travelers grew frustrated.

In response, Congress passed the Aviation Security Stakeholder Participation Act of 2012, which created a public-private partnership that fostered dialogue. It was this collaboration that created TSA’s PreCheck, which both better focuses more robust security screening on those who present the most risk and improves the pre-cleared, known traveler’s experience. I’m confident that a similar security solution can be found for the gaming industry through its increased engagement and ongoing dialogue toward true public-private partnership with FinCEN.

Commitment to Compliance

The casino industry is committed to working in partnership with FinCEN as we do with all regulatory agencies—our industry has worked with more than 300 jurisdictions in the U.S. and more globally, for the decades that we’ve been in business.

FinCEN Director Calvery recently acknowledged in her remarks at the Bank Secrecy Act Conference in Las Vegas in June that meetings between her agency and the gaming industry are productive. It’s unquestionable that progress is being made. The AGA will continue to convene compliance and AML leaders to collaborate with FinCEN representatives in developing best practices for our industry and in improving the agency’s understanding of our commitment to compliance.

With increased information-sharing and focused efforts, we can achieve our common goal of protecting financial institutions while ensuring the safety and security of our business and the majority of our customers who play responsibly.

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