Despite the exhaustive vetting processes used by gaming regulators to determine the suitability of casino operators, casinos themselves have remained vulnerable to money laundering and terrorism financing. While gaming compliance personnel must submit a 66-page Multi-Jurisdictional Personal History Disclosure that details all personal financial holdings and checks written within the last three years,¹ casino patrons are able to gamble with far less scrutiny.

L Gambling Control Act-Business and Professions Code, Division 8, Chapter 5 l California Code of Regulations, Title 11, Division 3 (CGCC initiated) l California Code of Regulations, Title 4, Division 18 (DOJ/BGC initiated) l California Penal Code (PC) l Local Ordinance or Municipal Codes. GAMBLING ESTABLISHMENT COMPLIANCE INSPECTION CHECKLIST. Compliance & Risk Management Expert regulatory and compliance solutions designed to support your governance, risk and compliance strategies Read more » Data Read more » eLearning Industry-leading, customizable sector and role specific education and training solutions Read more ».

A 2015 U.S. Treasury report² identifies structuring, or dividing a large reportable transaction into multiple, smaller non-reportable amounts, and minimal gambling, where a player cashes out their chips after little or no play, as casinos’ most frequent anti-money-laundering (AML) risks. The good news is that a December 2016 assessment by the Financial Action Task Force (FATF) found that casinos are responding positively to the AML threat³. The FATF states, “The gaming industry has taken significant steps to comply with AML/CFT requirements and prevent potential money laundering and terrorist financing in the last five years.”

Still, recent regulatory actions by the Financial Crimes Enforcement Network (FinCEN), like the $22.5 million fine levied against CG Technology, L.P., a Cantor Fitzgerald affiliate last September⁴, or the million-dollar fine assessed to the Nugget Casino Resort last April, are cause for concern⁵.

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