Despite recent improvements in the gaming industry's efforts to combat money laundering, it’s apparent that casinos’ anti-money laundering (AML) programs and related internal controls are being subjected to greater scrutiny. Compliance officers are facing personal consequences for violations by their companies since a court confirmed the Bank Secrecy Act allows penalties against a "partner, director, officer, or employee."
For an effective AML program, casinos are required to maintain four fundamental pillars in addition to the reporting and record-keeping requirements: (1) Development of written internal policies, procedures and controls, (2) Designation of an AML compliance officer, (3) Ongoing AML employee-training program, and (4) Independent testing of the AML program. This article provides more background on casino AML programs and risks to look out for.