AML Compliance Developments In The Gaming Industry

Executives of regulated entities often lament that fulfilling compliance obligations interferes with their ability to operate their business. However, an extensive (and extended) regulator investigation with the potential for civil and / or criminal penalties can present an even greater obstacle to running a business.

Trends over the last year in the gaming industry suggest that Title 31 compliance remains a key focus of the industry's primary federal regulator, the Financial Crimes Enforcement Network (FinCEN). As a result, executives tasked with compliance at financial institutions such as casinos should be mindful of recent events that, taken together, may warrant a fresh look at the anti-money laundering (AML) compliance program currently in place.