Treasury’s Financial Crimes Enforcement Network (FinCEN). While the AMLA does not specifically mention casinos, the implications of the law are hard to miss, says Jeremy Kuester, a counsel at White & Case and a former Deputy Associate Director for the Policy Division of the U.S. It also raises the penalties for failing to disclose beneficial ownership information and neglecting to file appropriate Suspicious Activity Reports (SARs) and Customer Transaction Reports (CTRs). The AMLA raises expectations about the thoroughness of Customer Due Diligence (CDD) information that financial institutions are obligated to collect. On January 1, 2021, Congress enacted the Anti-Money Laundering Act of 2020 (AMLA), which significantly expands FinCEN’s regulatory powers and raises the maximum penalty for Title 31 BSA violations for individuals to $1 million and 10 years in prison. Since then, FinCEN has not issued any large penalties to casinos, but it has strengthened its enforcement capabilities and given potential future penalties much sharper teeth. In 2017, Artichoke Joe’s Casino in California was hit with an $8 million fine for allegedly, according to FinCEN, “turning a blind eye to loan sharking, suspicious transfers of high-value gaming chips, and flagrant criminal activity that occurred in plain sight.” The Anti-Money Laundering Act of 2020 Whereas FinCEN issued only three civil penalties against casinos from 2003 to 2014, totaling $1.6 million, it levied $110 million in civil penalties against casinos from 2015 to 2016 alone. Treasury’s Financial Crimes Enforcement Network (FinCEN) is ramping up its enforcement of Title 31, the portion of the Bank Secrecy act (BSA) that applies to casinos and card clubs. And unlike a bank, casinos are not legally required to collect a great deal of personal information from their customers before exchanging large sums of money.įor these and many other reasons, the U.S. Furthermore, a casino’s customers are often one-time visitors and people who move from state to state. Gaming is still largely a cash business, after all, and it’s not unusual for a customer to exchange thousands of dollars in a single visit.

Among non-bank financial institutions, casinos top the list of businesses that federal regulators are scrutinizing for evidence of money laundering - and it’s not hard to see why.

Casino gaming rule