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.”
The Financial Action Task Force (FATF) released its mutual evaluation report for the United States last week. FATF releases such reports once every 10 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.”
Ten years prior, FATF was critical of casino gaming. For example, it said, “Regulators and casinos should work to further harmonize the Nevada Gaming Commission’s (NGC) regulatory requirements with the Bank Secrecy Act (BSA) and that this should occur as rapidly as possible.”
“It’s no accident that FATF’s evaluation of the casino gaming industry greatly improved from 2006 to 2016,” said Geoff Freeman, AGA president and CEO. “We’re proud of the incredible strides the industry has made not only since FATF’s report of the gaming industry 10 years ago, but in the last three years as we’ve built a partnership with the federal government that serves as a model for other industries.”
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.”
In 2013 at Global Gaming Expo (G2E), the largest annual gathering of gaming industry professionals, then-FinCEN Director Jennifer Shasky-Calvery said, “I fear there may be a culture within some pockets of the industry of reluctant compliance with the bare minimum, if not less. I hope that together we can make a cultural change.” Today’s report offers the latest evidence that such a change has indeed occurred.
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.
