Part III: Business & Regulation · Banking, Chips & Financial Operations

AML Program

Compliance & ReportingVERIFIED

(1) An Anti-Money Laundering (AML) program is the comprehensive, written system of internal controls, policies, and procedures that a casino develops and implements to ensure compliance with the Bank Secrecy Act. A compliant AML program must include, at minimum: a system of internal controls to assure BSA compliance; designation of a compliance officer responsible for day-to-day oversight; ongoing training of appropriate personnel; independent testing of the program’s effectiveness; and procedures for using all reasonably available information to identify reportable transactions and verify customer identity. The AML program must be risk-based, meaning controls should be commensurate with the casino’s particular risk profile based on its size, location, customer base, products, and services. (2) A comprehensive, written risk-based compliance program that casinos are legally required to develop and implement to prevent money laundering and terrorist financing. An AML program must include at minimum: a system of internal controls to assure compliance with the BSA; designation of a dedicated BSA/AML compliance officer; ongoing training for appropriate personnel; independent testing (audit) of the program; and procedures for verifying customer identity, suspicious activity reporting, and record retention. Each AML program is unique to the casino and must be tailored to its specific risk profile based on gaming volume, financial services offered, patron characteristics, and geographic risk factors.

In practice

US requirements under 31 CFR 1021.210. Most Asia-Pacific jurisdictions have equivalent requirements under their national AML/CFT legislation modeled on FATF recommendations. FinCEN requires each casino to develop its own unique AML program based on a risk assessment of its operations. There is no “one size fits all” template. AML programs must be updated as risks evolve.

One entry from the Casino Industry Glossary, 1,090 terms written for surveillance, compliance and operations professionals rather than for players. Definitions describe industry usage; where a term carries a regulatory meaning, verify against the instrument that governs your jurisdiction.