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

69. AML Program

Compliance & Reporting

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.

In practice

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 — 1,157 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.