In August 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an advisory urging leadership within all U.S. financial institutions to actively promote a culture of compliance with respect to Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) requirements.
To date, FinCen’s gaming industry enforcement decisions have identified shortcomings in compliance programs at the company level. Efforts to ensure that compliance obligations are met should not stop at the company level, however. Enforcement actions against individual employees responsible for AML compliance may be the next phase of FinCen’s efforts to ensure BSA/AMl compliance within the gaming industry.
Originally published in the Autumn 2016 edition of American Gaming Lawyer (Vol. 12, No. 2).
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