Do Not Bet Against It: Heightened Scrutiny of Casinos Is Here to Stay


"What happens in Vegas, stays in Vegas" may still apply to bachelor parties, but it is no longer true for gaming. Just as the days of the discreet private banker have gone the way of the fax machine, so, too, has the halcyon era of anonymous gaming in land-based casinos. Recent events have made it clear that the Bank Secrecy Act (BSA) means what it says: The federal government will hold casinos to their obligation to develop effective systems to prevent money laundering.

The last days of 2014 brought two major developments impacting the future of large-scale casinos. On December 17, New York approved the development of three major casinos upstate" in the Finger Lakes region, the former "Borsch Belt" area of the Catskills and in the Capital District outside of Albany. Only weeks earlier, the American Gaming Association (AGA) published its first-ever Best Practices for Anti-Money Laundering Compliance (the Guidance), to protect land-based casinos from money laundering and financial crime risks. Both events followed on the heels of Massachusetts's licensing of three large-scale casinos earlier in the year.