AML Compliance for Casino and Gaming Industry

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As a Business in the Gaming industry, you’re likely well aware of the need for compliance with anti-money laundering (AML) regulations. But what exactly does that mean for your casino? Here’s a quick overview of AML compliance requirements for casinos and how you can ensure your business is meeting them.

In recent decades, as more jurisdictions have benefited from the tax income provided by legalized gambling, the casino and gaming business has experienced substantial growth. Due to the fact that casinos have a number of innate weaknesses that make them particularly vulnerable to money laundering, certain obligations and challenges that come along with this growth are also present. Therefore, in order to prevent financial crime, these organizations must comply with a variety of reporting and record-keeping regulations. They also need to make sure that proper anti-money laundering (AML) compliance mechanisms are in place.

What is a Casino? 

Simply said, A casino is a place where the public can play a variety of games of chance, with gambling serving as the major attraction.The average casino adds a range of luxuries to assist entice gamblers, including restaurants, free drinks, stage acts, and stunning scenery.

A casino is a place of business that provides gaming options like table games, slot machines, and video poker. Casinos also often provide other forms of entertainment, such as live music and shows. Many casinos are located near hotels or resorts, making them popular destinations for tourists. Casinos generate revenue from gaming activity in the form of house wins, player losses, and entrance fees. Casinos are also known for their high security measures, which help protect players, patrons, and employees from theft and other criminal activity.

Money Laundering Vulnerabilities in Casino Industry

Money laundering is a crime in which criminals attempt to hide their illicit activities from law enforcement by using legitimate businesses to conceal the source and destination of ill-gotten gains. The casino industry has several vulnerabilities which can be exploited for money laundering, including cash-based transactions, lack of customer identity verification, and large volumes of anonymous customers. Casinos can be especially attractive targets for money launderers due to the large amounts of cash they handle on a daily basis.

The casino industry is subject to stringent anti-money laundering laws and regulations, which have been adopted by most countries in an effort to reduce financial crime. The objective of these measures is to ensure that casinos are not used for money laundering, terrorist financing, and other illegal activities.

Addressing Challenges: Foreign Exchange Services and High Rollers

In order to comply with AML regulations, casinos must maintain effective customer due diligence policies. This includes verifying the identity of customers before allowing cash transactions and keeping detailed records of their gaming activity. Casinos are also required to undertake suspicious transaction monitoring in order to detect any unusual or suspicious behavior that may indicate money laundering. In addition, casinos must screen customers against watch list databases in order to ensure they are not conducting transactions with known criminals or terrorist groups.

Other serious challenges include the availability of foreign exchange services, the reduced transparency of some customers, such as “high rollers” in VIP rooms, and the use of foreign holding accounts, which make it easy for money in one jurisdiction to be used in a casino in a different jurisdiction.

There are numerous ways that casinos can be used for money laundering. In other instances, dirty money is turned into chips, used for a brief period of time of play, and then cashed out in the form of a check. Another method is for people to open many accounts using fictitious identities in order to prevent the tracing of illegal activity.

AML requirements for Casinos

Casinos that are subject to the Bank Secrecy Act (BSA) are required to adhere to anti-money laundering (AML) systems that contain protocols to identify and report suspicious activity, according to the Financial Crimes Enforcement Network. Any casino that violates the BSA may be subject to an investigation by the Financial Crimes Enforcement Network (FinCEN), including:

  • reporting suspicious activity (SAR) for transactions that are at least $5,000
  • reporting currency transactions (CTR) for withdrawals or cash-ins that exceed $10,000
  • maintaining certain records for up to five years, such as the money received by the casino for each client, the bookkeeping entries for the debits or credits made to the client’s casino account, and the credit extensions that exceed $10,000.
  • having AML compliance programs in place

AML/BSA compliance program for Casinos

Casinos in the US are subject to the Bank Secrecy Act (BSA). The financial intelligence division of the US, FinCEN, published guidelines for AML/BSA compliance programs,stating that such a program “at a minimum” must include:

  • Internal controls to guarantee ongoing adherence to the BSA
  • Independent internal or external testing to ensure compliance with a scope and frequency consistent with the threats posed by the offered goods and services to money laundering and terrorist financing
  • Training of casino staff, including instruction in spotting unusual or suspicious transactions
  • An individual or individuals to guarantee ongoing adherence to the BSA
  • using all available information, methods for identifying and validating a person’s name, address, social security number, or identification number of the taxpayer , and other identifying information as needed 
  • methods for analyzing all available data to identify any transactions or patterns of transactions that must be reported as suspicious
  • applications are used to help assure compliance for card clubs and casinos that use automated data processing systems.
  • Procedures for evaluating whether a record required by the BSA must be created and retained

Casino Money Laundering Red Flags to look out for

  • any player that buys a lot of chips, plays nothing at all, and then cashes them out.
  • Chips are bought by two or more buyers for a total of between $3,000 and $10,000 each. Customers then play a limited amount of games and combine their chips before one of them makes a withdrawal.
  • when a player attempts to cash out chips for more than $10,000 but is asked for a Currency Transaction Report (CTRC), after which the player lowers the value to under $10,000.
  • To avoid filling out the CTRC form, person asks someone else to cash out a portion of the chips.
  • Someone tries to bribe or conspire with a worker to avoid filing a CTRC form.

Suspicious Activity Reporting requirements for Casinos

Casinos must submit suspicious activity reports (SARs) and currency transaction reports in addition to implementing extensive and effective anti-money laundering compliance processes (CTRs). These BSA recordkeeping standards must be followed by casinos for up to five years.

Casinos must be well aware of their responsibility to report suspicious activity. Under the BSA, casinos are required to report certain transactions that may indicate money laundering or terrorist financing, including :

  • below CTR Threshold Transactions
  • Unidentified Source of chips
  • When Two or More People Work Together
  • Transaction Modification or Cancellation to Avoid CTR Requirement
  • Concerns about the Source of the Funding

Additionally, casinos must submit CTRs to FinCEN for any cash-ins or cash-outs that exceed $10,000 within a 24-hour window. This calls for the collection of currency exchange rates from a variety of casino locations, such as the gaming tables, video gaming consoles, and cage activities, which includes credit (or marker limit) and front-money exchange rates. As part of this requirement, a casino must also receive money from each customer, record debits and credits to that customer’s casino account, and extend credit of more than $10,000.


Gambling establishments are prime targets for money laundering and other forms of financial crime due to the massive amounts of money that pass through casinos on a daily basis. Because of this, casinos are subject to the same level of regulatory oversight as banks and other financial institutions.

In fact, the gambling industry’s AML compliance has come under heightened scrutiny from FinCEN and other regulatory bodies. To successfully detect and prevent money laundering and other financial crimes, casinos and other gaming businesses must maintain current processes and procedures.

While developing an AML compliance program may appear difficult, casinos must do so in order to safeguard both themselves and their patrons. Casinos may avoid money laundering and maintain a secure and legal gaming environment by adopting these measures.

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