New Standards Adopted In US Gaming

The American Gaming Association (AGA) released an updated set of compliance standards for the US Casino industry last week, which is estimated to be worth $240 billion and employ 1.7 million Americans. The new standards follow a report released at the end of 2016 in which the Financial Action Task Force (FATF) lauded its praise on the American casino industry for what it called, “an increased focus on raising awareness and improving compliance” in regard to illicit gaming activity, such as money laundering.

The Best Practices for AML Compliance (2023) were released in concurrently with the industry standard Culture of Compliance film in an effort to further direct momentum. The updated Best Practices align with new control methods from the Financial Crimes Enforcement Network (FinCEN). Special focus is placed on casino industry cooperation with law enforcement, particularly with the U.S. Treasury Department. The guidelines are only the latest in a series that has been evolving since the first draft was published by the AGA in 2014.

President and CEO of the AGA, Geoff Freeman, contributed briefly in the press release on the updated Best Practices, offering, “Our industry’s commitment to a culture of compliance is stronger than ever, and our updated Best Practices ensure that casinos of all sizes are protecting themselves and America’s national security,” placing emphasis on government cooperation, he went on to state, “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.”

According to the AGA press release, the following updates have been added to the Best Practices for 2023:

• Enhanced emphasis throughout the entirety of the updated Best Practices 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 the 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;
• Incorporation of key conclusions regarding potential risks in casinos from the Treasury’s National Money Laundering Risk Assessment; and
• Employee training section enhancements to ensure that employees receive timely updates on developments in laws, regulations and Government issued guidance.

(CASINO INDUSTRY UNVEILS NEW BEST PRACTICES FOR ANTI-MONEY LAUNDERING COMPLIANCE. (2023). Retrieved from https://www.americangaming.org/newsroom/press-releasess/casino-industry-unveils-new-best-practices-anti-money-laundering-compliance)

AGA Best Practices Outlined

Beyond the most recent amendments and updates, the Best Practices cover a wide range of compliance regulations for operators, service providers, and employees to adhere to as part of the casino industry.

Risk assessment spans a wide range of topics not only used to identify potentially damaging behavior among players, but also political liabilities among patrons, game characteristics and financial services.

Employee training is outlined alongside customer due diligence and audit procedures. Transaction monitoring and potentially suspicious financial activity are in place to negate instances of fraud and identity theft.

While casino activity among employees and patrons are among the focal points outlined in the document, record keeping and retention standards are also in place to negate instances of conflicting reports between operators, patrons, and/or governing bodies.

The American Gaming Association

While each individual casino operator has outlined their own compliance and regulatory procedures in-line with the statutes of their state and the federal government, the AGA seeks to be the unifying body of the casino industry nationwide and provide a source of Best Practices in an effort to be the definitive entity of the industry, providing avenues for growth, innovation, and reinvestment.