Industry updates anti-money laundering guide

Almost a year after the gaming industry released its first comprehensive guide on anti-money laundering practices, the American Gaming Association has released updates to help operators come into and stay in compliance with U.S., banking laws.

The guide, “Best Practices for Anti-Money Laundering Compliance,” was originally developed in partnership with the Financial Crimes Enforcement Network, or FinCEN, and with compliance representatives from a broad array of AGA member companies.

“Our industry’s commitment to a culture of compliance is stronger than ever,” Geoff Freeman, president and CEO of the AGA, said in a statement. “We will continue to bolster these best practices, adapt to evolving threats and incorporate guidance from FinCEN and other regulators.”

Freeman said this ongoing effort was to prevent “illicit activity from occurring at gaming properties.”

Among the updates are an enhanced emphasis on the importance of instilling a strong culture of compliance, aligned with FinCEN’s guidance; more targeted and extensive assessment of money laundering risks, focused on various aspects of a casino, including gaming floor activity, race and sports book activity; cage-focused activity and information from the back of the house.

Other updates include incorporation of key conclusions regarding potential risks in casinos from the U.S. Department of Treasury’s National Money Laundering Risk Assessment; and employee training updates so employees get the latest developments in laws, regulations and government-issued guidance.

These latest updates come as the federal government has cracked down on alleged money laundering through casinos.

The FBI this month raided two San Diego card rooms alleging they were the conduit through which dirty money from an illegal gaming operation was laundered. The FBI alleges the illegal gambling operation laundered $10 million.

Caesars Palace on Sept. 8 agreed to pay $9.5 million in fines for failing to properly guard itself against money laundering. FinCEN said Caesars Palace neglected to apply proper scrutiny and “allowed some of the most lucrative and riskiest financial transactions to go unreported.”

FinCEN also alleged Caesars Palace promoted the private salons through branch offices in the United States and abroad, but did not appropriately monitor transactions such as large wire transfers for suspicious activity.

Caesars is not the only Las Vegas-based casino company that has settled with the federal government after facing scrutiny of their anti-money laundering procedures. In 2013, Las Vegas Sands Corp., which runs Venetian and Palazzo on the Strip, agreed to pay $47.4 million to settle a money laundering investigation.

For the 24-page AGA “Best Practices for Anti-Money Laundering Compliance,” log on to

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