Regulatory Alerts2014-12-24
FinCEN Correspondence with the American Gaming Association Regarding Sports Betting Conducted on Behalf of Third Parties
FinCEN warns the casino industry that sports betting conducted on behalf of third parties facilitates money laundering and poses significant risks to the U.S. financial system. The agency clarifies that casinos must implement risk-based Anti-Money Laundering programs to identify whether transactions are conducted for the patron or a third party to ensure accurate Currency Transaction Reports. Failure to identify third parties may constitute violations of Bank Secrecy Act recordkeeping and reporting obligations, potentially resulting in civil penalties or criminal prosecution.
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