Key Moments:
- The American Gaming Association has released its first update to the Best Practices for Anti-Money Laundering (AML) Compliance Guide since 2022.
- The revised guide introduces enhanced protocols for Know Your Customer (KYC), Suspicious Activity Report (SAR) filings, and addresses digital wallets, cryptocurrency, and trafficking risks.
- The new guidance places human trafficking within AML compliance, expanding the responsibilities of operators and compliance teams.
Responding to Digital Challenges in Gaming
With the expansion of land-based casinos, the legalization of sports betting in ten states, and the introduction of iGaming, the U.S. gaming sector has reached unprecedented scale and complexity. This growth has brought a surge in digital transactions, making the industry increasingly susceptible to fraud and criminal exploitation. In response, the American Gaming Association (AGA) has issued an updated Best Practices for Anti-Money Laundering Compliance Guide, marking its first revision since 2022. The update comes amid heightened scrutiny from regulators, who are demanding stronger protections for financial platforms and flows.
Shifting the Focus of AML Compliance
The newly released edition of the guide acknowledges that traditional concerns, such as cash chips and in-person cage transactions, no longer represent the entirety of AML risk. The updated rules include more rigorous requirements for customer due diligence and SAR filings, along with a comprehensive section on risk assessment tailored for today’s digital landscape.
This version places heavy emphasis on monitoring digital wallets, cryptocurrencies, and online operations – areas regulators now consider especially vulnerable. The document also expands directions regarding fraudulent activities and introduces, for the first time, detailed procedures for addressing human trafficking threats associated with money laundering.
Industry Perspectives and Regulatory Pressures
Leadership at the AGA is advocating for operators to adopt the revised guide as an evolving manual for AML best practices. Alex Costello, Vice President of Government Relations at the AGA, stated:
“Maintaining up-to-date AML policies is essential to safeguarding the gaming industry’s operations, employees, and customers – and to protecting the integrity of the U.S. financial system. We encourage all casino operators and suppliers to use this resource to continually refine their practices as both the industry and threat environment change.”
According to industry sentiment and regulatory attention in Washington, aligning closely with FinCEN and similar agencies is now more critical than ever.
Human Trafficking: A New Area of Emphasis
For the first time, the AGA’s AML guidelines explicitly cover human trafficking. This addition broadens the scope of AML compliance, requiring both land-based and online gaming platforms to monitor, identify, and report laundering activities linked to trafficking networks. Staff are provided with new red flags and procedural steps, elevating the importance of social responsibility alongside regulatory compliance.
Implications for Operators
The updated guidelines introduce several new compliance expectations and highlight that maintaining market access is as important as avoiding regulatory penalties. Operators are now directed to optimize KYC processes, oversee crypto and digital payment channels, enhance fraud detection and reporting mechanisms, and incorporate trafficking awareness into their compliance agendas. Robust collaboration with regulators and law enforcement is also strongly encouraged.
Key AML Updates | Operator Responsibilities |
---|---|
Enhanced KYC requirements | Comprehensive verification for all customers |
Real-time monitoring of digital wallets and crypto | Immediate detection of suspicious transactions |
Inclusion of trafficking risks | Staff training to recognize and report trafficking-linked activities |
Expanded SAR protocols | Prompt and thorough suspicious activity reporting |
Looking Ahead
As innovation in payment systems and digital technologies continues, so will the evolution of AML compliance frameworks. The AGA’s revised guide is intended not only to meet current requirements but to prepare operators for emerging threats, such as advanced analytics tools and the expansion of regulated online gaming. Staying ahead of criminal tactics and regulatory expectations is expected to remain a core challenge for industry participants, as the sector adapts to continuous change.
- Author
Daniel Williams
