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Department of the Treasury
Financial Crimes Enforcement Network


Issued: June 30, 2010
Subject: Casino or Card Club Compliance Program Assessment
This document describes factors that a casino or card club may need to consider in assessing the effectiveness of its Bank Secrecy Act (“BSA”) compliance program. The BSA requires casinos and card clubs to develop and implement compliance programs tailored to their business activities and risk profiles. A casino or card club may not need to address each of the factors described in this document. Also, a casino or card club should not construe the factors below as exhaustive and the only ones required to be addressed.

I. Elements of a BSA Compliance Program

A casino or card club is required to develop and implement a BSA compliance program that adequately addresses the risks posed by its products, services, customer base, and geographical location for the potential of money laundering and terrorist financing. At a minimum, each BSA compliance program1 must provide for:

II. Criteria for Assessing a BSA Compliance Program

A casino or card club may need to consider the following criteria, among others, when assessing its BSA compliance program:

III. Basis for Revising a BSA Compliance Program

Based on its assessment, a casino or card club should consider the following in determining whether to revise its BSA compliance program:

Deficiencies could result in BSA civil money penalties or other enforcement actions. Also, a casino or card club may need to consider corrective action, as appropriate. Deficiencies that may warrant taking corrective action include, but are not limited to the following:

In conclusion, an effective BSA compliance program should reflect a casino or card club’s products, services, customer base, and geographical location. It is a sound practice for a casino or card club to periodically re-assess its BSA compliance program to assure sufficiency and effectiveness.

For questions about this guidance, please contact FinCEN’s Regulatory Helpline at (800) 949-2732.


For additional guidance, see Casino or Card Club Risk-Based Compliance Indicators, FIN-2010-G002 (June 30, 2010) and Frequently Asked Questions – Casino Recordkeeping, Reporting and Compliance Program Requirements, FIN-2007-G005 (November 14, 2007) and FIN-2009-G004 (September 30, 2009), and Recognizing Suspicious Activity - Red Flags for Casinos and Card Clubs, FIN-2008-G007 (August 1, 2008). Other reference material includes Structuring by Casino Patrons and Personnel, FIN-2009-A003 (July 1, 2009). See also In the matter of the Tonkawa Tribe of Oklahoma and Edward E. Street - FinCEN No. 2006-1 (March 24, 2006).

1 See 31 C.F.R. § 103.64(a). Compliance with this requirement satisfies the obligation under Section 352 of the USA PATRIOT Act to implement an anti-money laundering (“AML”) program. See 31 C.F.R. § 103.120(d).