The American Gaming Association (AGA) has provided new guidance on how to better prepare and manage money laundering for its members. The report, Best Practices for Compliance with Anti-Money Laundering (AML), sets out the commitment of the industry to compliance and helps guide the efforts of casinos to protect the US financial system from money laundering and other forms of illicit finance.
Best Practices changes include a continued commitment to a positive compliance culture and the value of government and law enforcement interaction with industry.
The paper also includes an in-depth analysis and updated guidance on new and emerging types of gaming, including the expanding market for US sports betting and online (mobile) gaming.
Based on the guidance and enforcement action taken by FinCEN, the National Money Laundering Risk Assessment of the Treasury Department and the updated compliance guidelines of the Office of Foreign Assets Control, the updated Best Practices includes a more robust risk assessment section and enhanced Know Your Customer Due Diligence measures.
In 2014, gaming became the first industry to develop a comprehensive set of AML compliance best practises collectively. Best Practices and compliance efforts with the Bank Secrecy Act of AGA were commended by the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury.
Bill Miller, President and CEO of the American Gaming Association said:“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. 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.”