Sunday, December 7, 2014


The American Gaming Association, the gambling industry's trade organization, has published a "Best practices for Anti-Money Laundering Compliance " guide for its members. In addition to covering much of what we have come to regard as banking best practices, the risk-based program also details the unique threats posed by money launderers operating in the American gaming industry.

The topics:

(1) Risk Assessment.
(2) BSA/AML Officer.
(3) Employee Training.
(4) Preventive Steps.
(5) Customer Due Diligence.
(6) Transaction Monitoring.
(7) Potential Suspicious Activity.
(8) Suspicious Activity Report Review.
(9) Audit Procedures.
(10) Recordkeeping and Retention.

PEPs, Country Risk and profiling are discussed in the 17-page document, which is written in plain English, and not legalese. Readers who wish to review the complete text of the guide can find it here*.

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