The American Gaming Association (AGA) has released an updated Best Practices for Anti-Money Laundering (AML) Compliance Guide in 2025, tightening regulations for the gaming industry amid rising digital risks. This is the first update since 2022, addressing the growing vulnerabilities that casinos and iGaming operators face with the surge of online financial dealings, cryptocurrency use, and human trafficking concerns.
Expanding Industry and Rising Digital Threats
The U.S. gaming industry has grown significantly, with over 1,000 land-based casinos nationwide, legalization of sports betting in ten states, and one state authorizing iGaming. This expansion has introduced a dramatic increase in digital payments, digital wallets, and the use of tokens, creating new opportunities for financial crime. Criminal elements have become quick to exploit these emerging digital channels, prompting the AGA to revise its AML guidelines to help operators better secure their platforms and financial flows.
Key Changes in the 2025 AML Guide
The updated AML guide shifts focus from traditional cash chips and in-person cage transactions to areas of digital risk. It introduces stricter Know Your Customer (KYC) protocols to ensure more robust customer due diligence across all channels. The guide also includes enhanced requirements for filing Suspicious Activity Reports (SARs) to improve fraud detection and reporting.
A significant addition is a comprehensive section on risk assessment tailored specifically to the digital landscape, with detailed guidance on managing threats connected to digital wallets, cryptocurrency transactions, and online gaming activities. This mirrors the regulatory view that these digital financial instruments present some of the highest emerging risks in the gaming sector.
For the first time, the guide explicitly addresses the risks of human trafficking linked to money laundering, requiring operators to monitor, identify, and report suspicious activities associated with trafficking networks. This broadens the scope of AML compliance to encompass social responsibility alongside financial safeguarding.
Industry and Regulatory Perspectives
AGA leadership emphasizes that the updated guide should be treated as a dynamic document, continuously refined to keep pace with evolving threats and technologies. Alex Costello, AGA’s Vice President of Government Relations, highlighted the importance of maintaining current AML policies for the protection of the gaming industry’s operations, employees, customers, and the integrity of the U.S. financial system.
The update has strong backing from regulators in Washington, who expect casino operators and online platforms to maintain close collaboration with FinCEN and other financial crime enforcement agencies. This alignment is crucial as operators face mounting pressure to detect and prevent illicit financial activities on their platforms.
Operational Implications for Gaming Operators
The revised guide significantly raises the operational bar for gaming operators. They now face several added responsibilities to maintain compliance and protect market access:
- Implementing more stringent KYC procedures during the onboarding and ongoing monitoring of customers.
- Establishing real-time oversight of digital wallets, cryptocurrencies, and token transactions to detect suspicious behaviors promptly.
- Training staff to recognize and respond to increasingly sophisticated fraud schemes and to file Suspicious Activity Reports without delay.
- Incorporating awareness and detection of human trafficking risks within their compliance frameworks.
- Enhancing collaboration with regulators, law enforcement, and other compliance stakeholders to strengthen overall defenses against financial crime.
Failure to meet these standards could trigger regulatory penalties and threaten the license status of operators in an increasingly competitive and scrutinized market.
Looking Ahead: Evolving AML Compliance
The AGA’s updated AML guide provides a current compliance roadmap but also signals future directions. The industry is expected to adopt advanced technologies such as AI tools and blockchain analytics to improve detection and monitoring of suspicious activity. As more states legalize iGaming and sports betting, the scope and scale of AML compliance will need to expand accordingly.
The guide reflects the AGA’s strong intent to keep the U.S. gaming industry aligned with financial system safeguards, promoting responsible growth in a digital era while mitigating new and complex threats.