One month after the influential international Financial Action Task Force (FATF) praised the casino industry at large for “an increased focus on raising awareness and improving compliance” around anti-money laundering (AML) and illicit activity, the American Gaming Association (AGA) released an updated set of Best Practices for AML Compliance (2017) in conjunction with the industry’s Culture of Compliance video to strengthen casino gaming’s compliance efforts.
The updated Best Practices incorporate critical aspects of new guidance by the Financial Crimes Enforcement Network (FinCEN), and an enhanced emphasis on a strong culture of compliance and industry engagement with law enforcement. AGA first released its set of Best Practices in 2014 after more than a year of work to identify and enhance industry guidelines.
“Our updated Best Practices ensure our industry’s commitment to a culture of compliance that prevents illicit activity,” said Geoff Freeman, president and CEO of the AGA. “The casino gaming industry is committed to working with FinCEN, the Treasury Department, law enforcement and other regulators to identify evolving threats and prevent any illegal activity from happening at gaming properties.”
This resource guides the effort of casinos to protect the U.S. financial system and America’s national security from money laundering and other forms of illicit finance. The landmark first version of the document was developed in coordination with FinCEN and with compliance representatives from a broad array of AGA member companies.
Among the key updates to the Best Practices are:
• Enhanced emphasis on the importance of instilling a strong culture of compliance, aligned with FinCEN’s guidance and as further illustrated in the gaming industry’s Culture of Compliance video;
• Incorporation of key components of new FinCEN guidance, including on cyber events and email compromise schemes; and
• Enhanced focus on the importance and value of industry engagement and partnership with government and law enforcement.
Casino companies have developed robust risk-based programs that promote compliance with the requirements of the federal Bank Secrecy Act (BSA) and associated AML regulations to discourage illicit behavior and safeguard the integrity of the casino industry. Risk-based compliance efforts are essential to the casino industry’s effective implementation of AML controls.