San Diego AML 2027

The AML regulatory environment continues to evolve as governments and regulators respond to emerging financial crime risks, new technologies and changing enforcement priorities. This session examines significant developments affecting casino AML programs in the United States while placing them within the broader global AML landscape. Attendees will explore what these developments may mean for casino compliance programs, risk management and future regulatory expectations.

This introductory session traces how anti-money laundering efforts developed and why casinos became part of the broader financial crime framework. Attendees will learn the core language of AML, including commonly used acronyms, terms and definitions, and how those concepts appear in casino operations. The session establishes a shared foundation for the more detailed reporting, investigation and risk sessions that follow.

Effective suspicious activity reporting begins long before a SAR is filed. This session examines how casino professionals identify unusual activity, investigate red flags and determine whether activity warrants reporting. Attendees will explore how to develop clear SAR narratives that communicate the who, what, when, where, why and how of suspicious activity.

What happens after a casino submits a SAR? This session provides a law-enforcement perspective on how SAR information may be reviewed, analyzed and connected with other investigative information. Attendees will learn which information can make a SAR particularly useful and how casino observations can contribute to investigations beyond the casino floor.

OFAC compliance presents unique challenges in a casino environment involving high transaction volumes, international customers and multiple points of customer interaction. This session examines sanctions-related responsibilities and practical considerations for integrating OFAC controls into casino operations. Attendees will explore screening, escalation and response considerations through a casino-specific lens.

Attendees will work through realistic casino scenarios and apply the concepts presented throughout Day One. Participants will identify red flags, determine what additional information should be gathered and decide whether the circumstances warrant suspicious activity reporting. Groups will consider what information belongs in the SAR and evaluate the case from casino and law-enforcement perspectives.

This session takes a closer look at the U.S. AML regulatory landscape, with a focus on FinCEN’s proposed rules and their potential implications for casinos. Attendees will examine the direction of proposed changes and how they could affect risk assessments, AML program design and day-to-day compliance work. The discussion will distinguish current obligations from proposals so attendees can identify what to monitor and where to prepare.

Having AML policies and procedures is not the same as having an effective AML program. This session examines how internal and external audit techniques can evaluate whether controls work in practice. Attendees will explore testing strategies, common weaknesses and ways audit findings can strengthen policies, procedures and risk management.

What is it actually like to experience an AML examination from the casino operator’s side? This panel discusses preparing for and navigating an examination, including information requests, documentation, interviews and internal coordination. Panelists will share lessons and practices that can help organizations remain examination-ready.

Casino AML teams have access to enormous amounts of data, but more data does not automatically produce better intelligence. This panel explores how technology, analytics and artificial intelligence can help professionals connect information, identify patterns, prioritize alerts and investigate risk. Panelists will address limitations of technology and where human judgment remains essential.

A meaningful AML risk assessment should guide where an organization directs resources and attention. This session examines how customer, product, transaction, geographic and operational risks can be evaluated within a complex gaming environment. Attendees will consider how assessments remain useful as casino operations and threats evolve.

Attendees will apply Day Two concepts to a hypothetical casino environment containing competing AML risks, limited resources and imperfect information. Groups will identify significant risks, determine immediate priorities and decide where resources should be allocated. Participants will compare approaches and discuss how different casino environments can reasonably produce different priorities.

This session examines recent Nevada gaming compliance developments and what they may signal for casino AML programs. Attendees will review relevant requirements and expectations and consider operational implications for compliance personnel, casino management and other stakeholders. The discussion will consider lessons organizations outside Nevada may take from Nevada’s evolving approach.

An effective AML program depends on more than the compliance department. Player Development, Slots, Table Games, Cage, Security and other teams see different pieces of customer behavior that become meaningful together. This session explores how casinos can build a culture in which employees understand their AML responsibilities and know when and how to escalate concerns.

AML programs are evaluated by stakeholders with different responsibilities, priorities and perspectives. This panel brings together audit, regulatory, tribal gaming and legal viewpoints to explore how each evaluates AML risk, controls and effectiveness. Understanding these perspectives can help compliance professionals anticipate concerns and build defensible programs.

Understanding who a customer is and whether their activity makes sense is central to effective casino AML. This session examines practical approaches to source-of-funds inquiries and real-time customer investigation using information available inside and outside the casino. Attendees will learn how separate pieces of information can be combined into a more complete understanding of customer activity.

Attendees will receive a fictional casino customer profile and investigate as additional information is progressively revealed. Participants will analyze gaming activity, transactions, customer information and potential sources of funds to determine whether the activity makes sense. Teams will decide what additional information they need, when escalation is appropriate and how to document conclusions.

AML leaders often understand program needs but face the challenge of communicating them to executives competing for limited resources. This session explores how to translate AML risks, operational weaknesses and technology needs into a compelling business case. Panelists will discuss how to communicate priorities in terms senior leadership and boards can understand and act upon.