The American Gaming Association (AGA) has recently released a significant update to its Anti-Money Laundering (AML) Best Practices Compliance Guide, marking the first major revision since 2022. This updated guide comes at a critical time when the gaming industry in the United States is expanding rapidly, accompanied by evolving financial crime risks largely driven by the rise of digital technologies and online gaming activities.
The 2025 edition of the AGA’s AML guide reflects the shifting landscape of the gaming sector. While traditional concerns such as cash and chip transactions remain, the guide places a new and intensified emphasis on digital payments, cryptocurrency, and online financial activities—areas that regulators have identified as some of the most vulnerable to money laundering and related criminal exploits. The updated guide also strengthens protocols around Know Your Customer (KYC) processes and Suspicious Activity Report (SAR) filings, which are key tools to detect and report suspicious financial behavior.
Moreover, this update incorporates a dedicated section on risk assessment, helping operators better identify and manage emerging AML risks. A novel and noteworthy inclusion in this edition is the focus on human trafficking as part of the AML compliance framework. The gaming industry, with its high volume of financial transactions and diverse customer base, is now being advised to look beyond financial crime to address social risks, including trafficking that can be connected to laundering proceeds through gaming venues or online platforms.
The legal gaming market in the U.S. has seen substantial growth: with over 1,000 land-based casinos operating nationwide, ten states legalizing sports betting, and the emergence of regulated iGaming. These expansions bring innovations like mobile wallets and faster payment methods, which, while improving customer experience, widen the scope of risks and require more vigilant compliance measures. The updated guide is designed to equip gaming operators with a comprehensive compliance framework that addresses these complex risks, balancing effective AML controls with the need to maintain seamless customer interactions.
Industry leaders emphasize that AML compliance should be a continuously evolving effort. Alex Costello, Vice President of Government Relations at the AGA, stated, “Maintaining up-to-date AML policies is essential to safeguarding the gaming industry’s operations, employees, and customers – and to protecting the integrity of the U.S. financial system. We encourage all casino operators and suppliers to use this resource to continually refine their practices as both the industry and threat environment change.”
In addition to updated regulatory expectations, the guide highlights that compliance programs must be risk-based, proactive, deeply embedded in business operations, and audit-ready. This means programs should be tailored according to the specific risks of customer profiles, geographic factors, and the methods of transactions while continuously adapting to emerging threats, regulatory guidance, and enforcement trends. Documentation and evidence supporting compliance efforts must be meticulously maintained for regulatory audits.
A further innovation in the 2025 guide involves detailed typologies of fraud schemes and enhanced red flag indicators to help frontline staff identify suspicious activities more effectively. The expansion of this guidance into the domain of human trafficking notably broadens the scope of AML compliance responsibilities. The AGA’s update instructs operators on identifying potential trafficking-related red flags and steps for reporting, underscoring social responsibility alongside regulatory compliance.
This updated guide represents an important collaborative effort between the U.S. gaming industry and regulatory bodies, including FinCEN, to sustain the sector’s leadership in AML compliance. The American gaming industry’s commitment to this cause is underscored by its ongoing dialogue with law enforcement and compliance experts to respond dynamically to new technologies, regulations, and emerging criminal methods.
Ultimately, the AGA’s 2025 AML Best Practices Guide provides gaming operators — from casinos to online platforms — a detailed, actionable blueprint to confront today’s and tomorrow’s AML challenges. By embracing these updated practices, the industry can protect itself against financial crimes while supporting broader efforts to prevent human trafficking and uphold the integrity of the financial system and society.
Key Highlights of the AGA 2025 AML Best Practices Guide
| Aspect | Description |
|---|---|
| Enhanced KYC and SAR Protocols | Stricter Know Your Customer verification and Suspicious Activity Report filing guidance to strengthen detection and reporting of suspicious activities. |
| Focus on Digital and Crypto Risks | Detailed guidance on managing risks associated with digital wallets, cryptocurrencies, and other online financial activities. |
| New Risk Assessment Section | Comprehensive approach to ongoing risk evaluation tailored to evolving threats and technologies. |
| Human Trafficking Integration | First-time inclusion addressing the risks of human trafficking through AML compliance with specific red flags and reporting protocols. |
| Industry Growth Considerations | Adapts compliance approaches to expansion in sports betting, iGaming legalization, and new payment methods like mobile wallets. |
| Compliance Culture Emphasis | Encourages active leadership engagement, resource allocation, and integration of compliance across operations to foster a strong anti-money laundering culture. |
Importance and Impact
The updated guide arrives when the U.S. gaming industry faces unprecedented growth and complexity, with digital transformation accelerating opportunities for criminals to exploit financial channels for illegal activities. Operators who adopt these updated best practices will not only comply with regulatory demands but also contribute to a safer and more transparent gaming environment. This helps protect customers, employees, and the broader financial system, reinforcing the industry’s reputation and sustainability.