REDW on Leaked FinCEN Files: Casinos’ Suspicious Activity Reports

REDW on Leaked FinCEN Files: Casinos’ Suspicious Activity Reports

December 16, 2020


In September, Buzzfeed News and the International Consortium of Investigative Journalists (ICIJ) reported on documents leaked from the Financial Crimes Enforcement Network (FinCEN), which is the Department of the Treasury’s bureau tasked to:

“safeguard the financial system from illicit use and combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities.†[1]

This reporting, known as the “FinCEN Files†sent shockwaves across the financial services industry—and ultimately cast a spotlight on the performance of casino management to monitor suspicious activity.

Largely, casinos have fulfilled their compliance duties in regard to FinCEN, but FinCEN and law enforcement agencies have historically lacked sufficient funding, resources and information-sharing capabilities to effectively pursue and root out illicit use of the financial system. According to their own records, FinCEN receives an average of 2 million Suspicious Activity Reports (SARs) a year and yet employs only about 300 employees. How can one government agency so small possibly review and analyze 2 million SARs a year looking for bad actors?

Coincidentally, in September, FinCEN published an advanced notice of proposed rulemaking requesting public comment on potential regulatory amendments that would “explicitly define an effective and reasonably designed anti-money laundering (AML) program.†If implemented these changes could place an additional burden on gaming organizations and their AML programs.

Learn more from REDW Experts in our latest article, “Gaming Industry Suspicious Activity Reporting (SAR) in Leaked FinCEN Files“:

Contact REDW Gaming Experts for AML Guidance

For questions regarding preparations for your AML programs, please contact REDW’s AML, Title 31, and casino gaming specialists Adam Smith, Joe Smith, or Anh K. To.


REDW is committed to keeping you informed at all times, and especially through the impacts of the COVID-19 pandemic. Stay connected with us on LinkedIn and @REDWLLC on Twitter. Access some of our other updates on our COVID-19 Resource Hub.

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