Gaming & AML Compliance
Casinos and gaming operators have long been defined as “financial institutions” because the industry handles billions of dollars in transactions each year. As one of the most heavily regulated business sectors in the world, the American gaming industry operates within a rigorous anti-money laundering (AML) framework that safeguards operations, employees and patrons, while protecting the integrity of the U.S. financial system.
Money laundering is an ever-evolving threat, and for gaming operators, staying ahead of these risks requires vigilance and collaboration. That means maintaining strong know-your-customer standards, robust internal monitoring controls, comprehensive risk assessments, and ongoing employee training to identify risks and red flags.
The U.S. gaming industry works directly with the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), and in close coordination with state regulators and law enforcement. These partnerships are critical to understanding the threat landscape and strengthening information-sharing across industries to identify emerging risks and bad actors seeking to exploit financial systems, including the gaming industry, for illicit purposes.
The American Gaming Association and our members are leaders in the industry’s efforts to uphold the highest standards of compliance, integrity and responsibility. Effective AML programs require a coordinated approach between the private sector and all levels of government. The AGA convenes a Bank Secrecy Act (BSA) Working Group where members collaborate on compliance challenges and share best practices. These discussions help identify trends, inform policy priorities and continuously strengthen the effectiveness of AML programs across the industry.
Last year, the AGA updated its Guide for Anti-Money Laundering Compliance, which distills best practices for a wide range of gaming businesses and incorporates feedback from our members and compliance professionals. The guide provides clear, actionable guidance for operators on everything from governance and risk-management protocols to patron due diligence, reporting and information-sharing. By standardizing best practices, the guide helps ensure that AML efforts are both compliant and effective in mitigating financial crimes in the gaming industry.
Training remains a cornerstone of effective prevention. Employees on the front lines play a critical role in identifying unusual activity and raising red flags that lead to suspicious activity reports (SARs) and help respond to—and often prevent—criminal activity. From AML officers to cage personnel to blackjack dealers, these employees are the “eyes and ears” of AML efforts in gaming.
In April, we hosted our annual AML Summit convening regulatory officials, law enforcement and financial industry partners to further discuss the latest trends, challenges and opportunities in gaming industry AML compliance. Topics included recent federal rulemaking, working with state regulators and ongoing risks posed by illegal and unregulated operators, including prediction markets offering sports event contracts.
Illegal gaming remains a major threat to the American public. Too often, consumers do not know the difference between a safe, legal online platform and an unregulated one operating outside the safeguards required under the BSA. Illegal operators lack the monitoring systems, integrity protocols and oversight required of legal operators, making them an attractive target for money launderers and other bad actors.
Illegal operators also undermine the reputation of the legal gaming market. As policymakers continue to address the illegal market, it’s critical to recognize that strong, regulated gaming environments provide the transparency and accountability necessary to combat financial crime.
While AML is certainly about compliance, it’s also about trust. Players, regulators and the public must be confident that legal gaming operators are committed to preventing financial crime, protecting consumers and upholding the integrity of both the gaming industry and the broader financial system. Through proactive and rigorous policies, robust training, transparency and public-private collaboration, the gaming industry continues to lead by example.
Alex Costello is vice president, government relations fot the American Gaming Association.
