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ITG FAQ #7 Answer-If a tribe has several casinos, is each casino required to have a separate anti-money laundering (AML) program?

An effective AML program is designed to prevent the casino from being used to facilitate money laundering and terrorist financing, and must be based on an assessment of the possible risks of those things happening. Each casino should have its own, risk-based, compliance program and compliance officer if they have different potential risks because of different circumstances, such as different types of games and patrons. Other factors such as the distance between casinos and the use of separate record keeping systems may increase the need to have a separate compliance officer for each location.

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Page Last Reviewed or Updated: 12-Oct-2016