Risk-based AML critical for casinos


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U.S. casinos are all subject to the anti-money laundering regulations found in the Bank Secrecy Act, and FinCen would like them to use a risk-based approach. However, AML controls remain in development at a lot financial institutions like casinos, and if reports coming out of Las Vega are correct, various U.S. authorities are shining a bright light on the AML controls used by the Wynn Resorts casino operations.

The Wall Street Journal reported late last month that prosecutors from both the New York and Las Vegas U.S. Attorneys offices and investigators from the IRS and DEA are conducting a joint investigation related to anti-money-laundering enforcement requirements.

According to the report, U.S. authorities are dedicating more resources to investigations of non-bank financial institutions such as casinos, which “conduct a large amount of cross-border and cash transactions.” The Wynn Resorts operation is the third large Vegas-based casino to attract close scrutiny in recent years.

Wall Street Journal, which reviewed some of the investigative demands made to the Wynn Resorts, said that investigators are seeking lists of the casino’s biggest customers since 2011 along with identity documentation such as birth dates, Social Security numbers, and related proof of identity. Investigators also want details about the company’s AML controls and its biggest customers by geographic region. Areas of special interest appear to be credit programs, sports betting, services extended to VIP customers, the identity and source of cash of certain customers, and transactions among its high-roller customers.

FinCen works with casinos to educate them regarding their legal obligations as complex financial institutions to comply with AML regulations. In a speech in June, FinCen Director Jennifer Shasky Calvery addressed industry professionals and urged them to take a “risk-based approach” to AML, an approach that should come naturally in an industry governed by risk analysis in its approach to betting and games.

AML Partners, which has helped pioneer risk-based software analytics for AML and other behavioral risks, has transformed FinCen recommendations and the BSA regulations into the SURETY Suite of comprehensive risk-based software for AML core compliance. Elements of the suite include SURETY-CDD®, SURETY-Behavioral Monitoring, and SURETY-Sanctions Screening.