The newest edition of the American Gaming Association’s Best Practices for Anti-Money Laundering Compliance Guide signals an inflection point for US casinos. With more than 1,000 land-based casinos operating nationwide, ten states legalizing sports betting, and iGaming expanding into new jurisdictions, the gaming industry has never been more visible in the financial system. Criminals have noticed as well. Every new wallet integration, digital betting option, or VIP service provides fresh channels to disguise illicit wealth. The AGA guide is therefore more than a handbook. It is a survival blueprint for an industry that must prove it can grow responsibly without becoming a magnet for financial crime.
Casinos are subject to one of the world’s most intensive regulatory environments, combining state-level licensing regimes with federal obligations under the Bank Secrecy Act. Beyond entertainment, casinos provide financial services: check cashing, wire transfers, front-money accounts, and increasingly cashless wallets. These features make them vulnerable. Patrons arriving for a weekend of leisure are indistinguishable, at least superficially, from actors intent on layering criminal proceeds. The AGA guide does not treat compliance as optional. It sets a tone of risk-based vigilance, recognizing that effective AML programs protect not only the institution but the integrity of the broader financial system.
Table of Contents
AML compliance guide shaping casino safeguards
The guidelines begin with governance. Board members and senior executives are reminded that accountability rests with them, not just compliance teams. They must approve AML/CFT programs, provide sufficient resources, and demonstrate knowledge of the requirements. The guide stresses culture of compliance as a real performance metric, with compensation structures that reward adherence and penalize shortcuts. Staff are urged to view compliance as an operational priority rather than an external imposition.
The governance chapter also highlights the AML Officer role. Far from being symbolic, the officer must be independent from gaming operations, empowered to escalate issues, and equipped with authority to brief top leadership. The guide suggests formal channels for reporting, including anonymous hotlines and documented investigation procedures, to ensure concerns are raised without fear of retaliation.
A critical dimension is risk assessment. Casinos are expected to map every entry and exit point for funds: cages, markers, digital wallets, sportsbooks, and even promotional credits. They must evaluate which services create disproportionate laundering risks, whether high-stakes poker rooms or online accounts with multiple payment instruments. Annual risk assessments are mandatory, with additional reviews when products or mergers alter the landscape. Regulators want to see that casinos identify residual risks and implement concrete action plans rather than leaving vulnerabilities unresolved.
The guidelines recognize that risk evolves with technology. Online platforms must apply geolocation checks, block suspicious devices, and detect “impossible travel” scenarios where accounts log in from geographically incompatible regions within short timeframes. Casinos are told to scrutinize minimal gaming activity paired with large deposits or withdrawals, a classic layering tactic. For cashless play and digital wallets, the rules emphasize alignment with KYC standards and require consistent linkage of accounts to a single verified identity.
Know Your Customer and suspicious activity reporting in practice
The Introduction and early chapters underline the necessity of strong KYC procedures. Casinos must collect names, addresses, Social Security numbers when applicable, and government-issued identification before permitting BSA-reportable transactions. For online onboarding, non-documentary verification using third-party databases, photo IDs, or selfies is encouraged. The guidelines recommend requesting supplementary details such as occupation or email when patrons approach transaction thresholds, reflecting the shift toward a holistic risk-based model rather than simple compliance box-ticking.
Enhanced diligence is mandatory for high-risk categories: politically exposed persons, foreign patrons from countries with capital controls, high-loss players, and patrons linked to illicit finance typologies. The guide goes further than past editions by explicitly urging casinos to analyze both source of funds and source of wealth. This dual assessment aims to ensure not only that a transaction’s immediate funds are legitimate, but also that a patron’s overall financial profile supports their level of gaming.
Suspicious Activity Reporting forms the backbone of detection. Casinos must file SARs for transactions aggregating at least $5,000 that show signs of illicit origin, structuring, or lack of lawful purpose. The rules remind operators that attempted transactions also qualify. The timeline for filing remains 30 days from detection, with a 60-day ceiling when suspects are not immediately identifiable. Importantly, the guide calls for robust escalation frameworks, where alerts move quickly from front-line detection to compliance investigation, avoiding bottlenecks that could compromise reporting deadlines.
Typologies described in the guide reflect real-world enforcement cases. Chip-walking, misuse of line-of-credit services, intra-property transfers that exploit multiple jurisdictions, and low-level structuring using ticket-in ticket-out kiosks are all cited. Casinos are instructed to review filed SARs annually to identify emerging patterns and adjust their programs accordingly. This continuous loop of detection, reporting, and refinement exemplifies the risk-based ethos regulators now demand.
Digital wallets, cryptocurrency, and the new frontier
Perhaps the most notable section of the 2025 update addresses online payments and digital wallets. The guidance recognizes that these tools blur the boundary between casinos and conventional financial institutions. Patrons can fund wallets through bank transfers, cards, or in-person deposits, then wager or withdraw with relative ease. While convenient, these features can be exploited for laundering if not carefully monitored.
The best practice is to restrict wallets to a single user, ensure withdrawals return to the original deposit method, and flag accounts that show deposit-withdrawal cycles without meaningful wagering. Casinos are reminded that while online transactions may not trigger Currency Transaction Reports, cash deposits or withdrawals at the cage still do, reinforcing the need for integrated oversight across platforms.
Cryptocurrency remains a special case. The guide advises casinos to require conversion of virtual assets into US dollars before gaming. This places the activity within the familiar framework of CTRs and SARs. The risk of anonymous or pseudonymous transfers is considered too high for direct use. By bringing crypto flows into the same reporting structure as cash, casinos reduce the chance of becoming a weak link in the financial chain.
The guidelines also issue a warning about shell companies and third-party payments. Accepting payments from anonymous entities, whether domestic or foreign, without documented relationships opens the door to illicit activity. Policies must explicitly define permissible third-party transactions, with approvals documented at senior levels. Anything less could attract enforcement scrutiny.
Raising the bar beyond casinos’ walls
The expanded guidance also reflects the broader ecosystem of AML/CFT expectations. Independent reviews, whether by external auditors or IRS examiners, must feed directly into risk assessments and trigger corrective actions. Recordkeeping requirements emphasize retention for at least five years, ensuring regulators can test whether decisions were justified and consistent.
Employee training receives special attention. Casinos are expected to provide not only onboarding sessions but ongoing, role-specific refreshers. Training should cover emerging typologies such as human trafficking, which now has a dedicated section in the guide. Staff must be able to spot indicators that link trafficking to gaming activity, such as third parties controlling patron accounts or groups of individuals exhibiting coercive patterns of play.
Information sharing is another pillar. The guide encourages use of Section 314(b) to coordinate with banks and other institutions, as well as maintaining open channels with law enforcement. By aligning reporting with federal priorities like the National Illicit Finance Strategy, casinos can show they are not merely meeting obligations but contributing to the national fight against financial crime.
The introduction to the document also stresses that casinos are financial institutions under the Bank Secrecy Act, a designation dating back to 1985. This legal identity cements their role in the US AML framework. They are not simply entertainment providers with ancillary compliance duties, but full participants in a financial system that depends on vigilance.
Protecting integrity while facing relentless evolution
The 2025 Best Practices demonstrate that the gaming industry acknowledges its dual identity: a source of entertainment and a financial gateway. With that comes responsibility. The guidelines are not exhaustive, nor do they provide a one-size-fits-all checklist. Instead, they establish principles that casinos must adapt to their unique risk profiles. The expectation is not mechanical compliance but demonstrable effectiveness.
Casinos that fail to internalize this message risk more than penalties. They risk reputational collapse in a sector where legitimacy has been hard won. By embedding culture of compliance, strengthening KYC, refining suspicious activity monitoring, and tightening controls over digital transactions, the industry can protect both its patrons and the US financial system. The AGA guide sets the standard. Meeting it is not just about avoiding fines. It is about ensuring that gaming’s future expansion is sustainable, responsible, and resilient against the ingenuity of criminals.
Related Links
- The American Gaming Association
- U.S. Treasury National Money Laundering Risk Assessment 2024
- OFAC Sanctions Programs and Information
- FinCEN Suspicious Activity Report Guidance
- U.S. Treasury Illicit Finance Strategy 2024
Other FinCrime Central Articles About Scrutiny on Casinos
- Summer Series #6: High-Stakes Compliance in Global Gambling Markets
- FINTRAC’s $1.17M Penalty on SIGA Exposes Money Laundering Failures
- Philippines Casino Losses of Officials Expose Flood Project Money Laundering Web
Source: The American Gambling Association
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