Director of the Financial Crimes Enforcement Network ("FinCEN") Kenneth A. Blanco highlighted the obligations of the gaming industry to develop, implement and enforce robust compliance programs and controls designed to fight fraud, money laundering and terrorist financing.

At the 11th Annual Las Vegas Anti-Money Laundering Conference and Expo, Director Blanco detailed the obligations that casinos have under the Bank Secrecy Act to comply with recordkeeping and reporting requirements. He noted that these reports are essential facets of domestic and international law enforcement efforts to combat financial crimes. This data, he said, provides leads, traces together networks, and helps to alert investigators to trends in illicit activity.

Director Blanco emphasized that establishing policies and procedures designed to make use of available information is an important aspect of identifying and deterring illicit activity. He asserted that casinos collect an "extraordinary" amount of information on their customers for marketing and customer relations purposes, and called for casinos to ensure that the information is used by appropriate compliance personnel.

Director Blanco pointed to ways in which information sharing through Section 314(b) of the USA PATRIOT Act can be useful, such as helping casinos gain a better understanding of their customers' sources of funds. He expressed concern that the number of Section 314(b) registrations for casinos recently declined, and strongly encouraged casinos to be active participants in the program.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.