The American Gaming Association (AGA) has published updated advice on how its members can better prepare and deal with money laundering. The report, Best Practices for Anti-Money Laundering (AML) Compliance, sets out the industry’s commitment to compliance and helps guide casinos’ efforts to protect the US financial system from money laundering and other forms of illicit finance.
Updates to the Best Practices include a continued commitment to a strong culture of compliance and the importance of industry engagement with government and law enforcement.
The document also offers a deepened analysis and updated recommendations regarding new and emerging forms of gaming, including the expanding US sports betting market and interactive (mobile) gaming.
Based on FinCEN’s guidance and enforcement action takeaways, the Treasury Department’s National Money Laundering Risk Assessment, and the Office of Foreign Assets Control’s updated compliance guidelines, the updated Best Practices contain a more robust risk assessment section, as well as enhanced Know Your Customer/Customer Due Diligence measures.
In 2014, gaming became the first industry to collectively establish a comprehensive set of best practices for AML compliance. The Best Practices and AGA’s Bank Secrecy Act compliance efforts have been commended by the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).
“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.”
Summarizing the updated advice, the AGA said: “The guidelines in this document must be adapted to match the specific circumstances of individual casinos and companies. Casinos should reconsider their AML/BSA compliance efforts on a routine basis to ensure they account for new risks and emerging patterns of illegal activity.
“When dealing with businesses as complex as modern casinos, and with judgments as subjective as those required by the BSA, no compliance effort can be perfect or immune from retrospective re-evaluation.
“Though perfection cannot be expected of a process that involves so many variables and periodic shifts in financial practices and regulations, effective AML/BSA compliance programs should ensure that the gaming industry continues to effectively combat money laundering or illicit financing threats.”