Yesterday, the American Gaming Association (“AGA”) released a report prepared by Ernst & Young evaluating the U.S. casino gaming industry’s AML compliance. According to the AGA, the report, Investing in America’s Financial Security: Casinos’ Commitment to Anti-Money Laundering Compliance,is “the most comprehensive examination ever conducted of the U.S. casino gaming industry’s compliance with federal AML laws and regulations.”

The report finds that casino gaming companies have significantly boosted their investment and vigilance to combat money laundering and terrorist financing in compliance with the federal Bank Secrecy Act (BSA) and associated AML regulations. It also finds that the industry has implemented a sweeping series of customer due diligence procedures to monitor illicit behavior, and has considerably increased the number of Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) filed with the federal government.

Notably, in December 2014, the industry released the first-ever Best Practices for AML Compliance, which details the various ways in which gaming companies should strengthen their compliance programs and incorporate best practices. An updated version of the Best Practices was released last month.

 “Gaming sets the standard for maintaining a strong culture of compliance through vigilant reporting, unprecedented investment in anti-money laundering compliance programs and a strong partnership with the federal government,” said Geoff Freeman, president and CEO of the AGA. “The casino gaming industry is dedicated to preventing money laundering, and this report proves it.”

This report comes ahead of the upcoming Financial Action Task Force (“FATF”) Mutual Evaluation, which will look at the U.S. systems for preventing criminal abuse of the financial system.

“In an environment where AML compliance is of paramount importance to the gaming industry, stakeholders have made great strides in preventing and detecting illicit behavior,” said Thomas Roche, Partner, Ernst & Young LLP, and the EY Global Gaming Services Leader. “These increased efforts have been acknowledged by regulators and law enforcement agents. Most regulators and officials we spoke with noted that casinos have improved the overall quality of regulatory filings pertaining to AML and continue to aid law enforcement investigation efforts.”

According to the FATF website, it conducts peer reviews of each country member on an ongoing basis to assess levels of implementation of the FATF Recommendations, providing an in-depth description and analysis of each country’s system and the financial sectors within them for preventing criminal abuse of the financial system.

FAFTA was established in July 1989 by a Group of Seven (G-7) Summit in Paris, initially to examine and develop measures to combat money laundering.  The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system. Starting with its own members, the FATF monitors countries' progress in implementing the FATF Recommendations; reviews money laundering and terrorist financing techniques and counter-measures; and promotes the adoption and implementation of the FATF Recommendations globally.



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