The American Gaming Association released an updated Best Practices for Anti-Money Laundering Compliance on December 9, practices which reflect the industry’s efforts to protect the U.S. financial system from money laundering and other forms of illicit finance.
In 2014, gaming became the first industry to collectively establish a comprehensive set of best practices for AML compliance. The U.S. Department of the Treasury’s Financial Crimes Enforcement Network, known as FinCEN has commended the AGA commitment.
The updated best practices contain a more robust risk assessment section, as well as enhanced Know Your Customer/Customer Due Diligence measures.
“As one of the most highly regulated industries in the United States, it is imperative we take every possible step to discourage illicit behavior and safeguard the integrity of the casino industry,” said Bill Miller, president and CEO of the American Gaming Association. “Through our ongoing partnership with FinCEN, the Treasury Department, and law enforcement, our industry continues to be a leader in compliance.”
Additional updates speak to the importance of engagement with government and law enforcement and recommendations regarding new forms of gaming such as U.S. sports betting and mobile gaming.
At last year’s Las Vegas Anti-Money Laundering Conference and Expo, FinCEN Director Kenneth Blanco credited the casino industry with providing information that helped uncover several money laundering transactions.
“I believe casinos are good and important partners that have made significant progress in recent years with respect to money laundering,” Blanco said in his prepared remarks, according to CDC Gaming Reports. “FinCEN is able to do important things with the data that casinos and other financial institutions provide every day.”
The relationship between the casino industry and FinCEN wasn’t always cozy. At the Global Gaming Expo in Las Vegas in 2013, then-FinCEN Director Jennifer Shasky Calvery told casino companies they needed to do more to combat money laundering. She made similar public comments a year later during a speech to a room full of gaming attorneys at the Bank Secrecy Conference at Red Rock Resort in Las Vegas.
Calvery’s 2013 remarks came a few months after Las Vegas Sands Corp. struck a deal with federal prosecutors and paid a settlement of $47.4 million to avoid criminal charges in connection with the money laundering activities at The Venetian in 2006 and 2007 by a high-end gambler who was allegedly linked to drug trafficking. Las Vegas Sands never faced Nevada gaming scrutiny over the settlement.
The last time a commercial casino was fined by FinCEN for anti-money laundering violations was in 2016, two years after the AGA instituted its original 2014 anti-laundering compliance efforts, CDC Gaming Reports said. The former operators of the Sparks Nugget in Northern Nevada paid a $1 million fine after admitting the property willfully violated the anti-money laundering provisions of the Bank Secrecy Act.
That same year, Nevada sportsbook operator CG Technology agreed to pay $22.5 million for its role in an illegal gambling and money laundering scheme. The settlement was the result a multipronged investigation that began in January, 2013. In 2015, Caesars Entertainment agreed to pay $8 million for violating the Bank Secrecy Act at Caesars Palace in Las Vegas during a three-month period in 2012. That same year, Trump Taj Mahal in Atlantic City paid a $10 million fine for Bank Secrecy Act violations.
