The Financial Crimes Enforcement Network (FinCEN) — a bureau within the U.S. Department of Treasury tasked with safeguarding the financial system from illicit use and combating money laundering — has recently fired multiple shots across the bow of the gaming industry, signaling increased attention to casino and cardroom compliance with the anti-money laundering (AML) provisions of the federal Bank Secrecy Act (BSA).
In 2016, three of FinCEN’s six enforcement actions were brought against companies in the gaming industry. In 2015, four of 12 enforcement actions were against such companies. In stark contrast, between 2002 and 2014, just four of FinCEN’s 57 enforcement actions were against gaming industry players.
MINIMAL GUIDANCE BEFORE 2015
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