Part III: Business & Regulation · Gaming Regulation & Compliance

AML Program

AML/CFT

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.

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.