Gambling on a Winning Compliance Program

BSA / AML Programs for the Casino Industry

Increasingly, regulators are challenging non-bank financial institutions to ‘step-up their game’ in building Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) Programs. The casino industry is currently a focus for the Financial Crimes Enforcement Network (“FinCEN”), the Department of Justice (“DOJ”) and the Internal Revenue Service (“IRS”). These regulators and enforcement agencies have imposed fines on a number of well-known casinos for AML violations within the past few years. It is in a casino’s best interest then, not to take any chances by relying on prior BSA/AML Program standards followed in the gaming industry. Instead, casinos may want to look to traditional financial institutions and model their BSA/AML programs against the more robust programs of these established banking organizations.

In this paper, Navigant experts Anne Minogue and Natasha Aronberg examine AML challenges for casinos and provide best practices for casinos to help guard against money laundering.

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