Share 
The American Gaming Association (AGA) has updated its Best Practices for Anti-Money Laundering Compliance Guide for casinos, making changes intended to keep operators and payment processors up to date on the changing landscape.
AGA Vice President of Government Relations Alex Costello said the update is an essential part of keeping the gaming industry safe and protecting the US financial system.
“We encourage all casino operators and suppliers to use this resource to continually refine their practices as both the industry and threat environment change.”
It’s the first update to the guide since 2022.
Human trafficking targeted in update
The AGA updated several parts of its anti-money laundering compliance guide, adding new recommendations and sections, including:
- Know Your Customer (KYC) protocols and Suspicious Activity Report (SAR) filings
- New guidance for risk assessment in the context of regulatory expectations
- Additional recommendations for online activity, digital wallets, and cryptocurrency
- More coverage on fraud risk
- New tips for spotting malicious activity
- New section focused on the intersection of human trafficking and money laundering
In the AGA compliance guide’s new human trafficking section, it notes that traffickers’ operations typically overlap with legitimate industries. The guide noted:
“This is especially true for the travel and tourism industry – including casino gaming – when properties are unwittingly used to facilitate criminal activity.”
The guide encourages casino employees to be aware of unusual behavior at casino cages, where money laundering and trafficking intersect, including individuals “being present for another person’s money transactions or who speaks on behalf of the customer conducting the transaction” or “filling out paperwork for another customer without consulting that person.”
Despite reporting by casinos, enforcement lags
Casinos operate under a variety of regulations and rules concerning money laundering. Specifically, according to Thomson Reuters, they adhere to the US Treasury’s Financial Crimes Enforcement Network’s four pillars of surveillance.
- Reporting cash transactions of more than $10,000
- Reporting suspicious activity
- Enforcing customer identification protocols
- Comprehensive recordkeeping
Generally speaking, casinos have done well in filing reports about suspicious activity, Thomson Reuters reported. However, enforcement from the Financial Crimes Enforcement Network (FinCEN) isn’t keeping up.
“Despite a massive surge in SAR filings, enforcement actions were virtually nonexistent, revealing a significant enforcement gap that undermines deterrence.”
In fact, financial institutions filed “tens of thousands” of SARs each year from 2020 to 2024, but only two FinCEN enforcement actions took place, according to Thomson Reuters.
“The current system generates massive volumes of reports but delivers minimal accountability. This, in turn, undermines the entire purpose of the SARs system and calls into question whether these reporting requirements are achieving their intended deterrent effect.”
