These frequently asked questions and answers are provided for general information only and should not be cited as any type of legal authority. They are designed to provide the user with information required to respond to general inquiries. Due to the uniqueness and complexities of Indian law and Federal tax law, it is imperative to ensure a full understanding of the specific question presented, and to perform the requisite research to ensure a correct response is provided.

  1. When are casinos considered to be financial institutions subject to requirements of the Bank Secrecy Act (Title 31)?
  2. Is a casino required to have an anti-money laundering (AML) program?
  3. Must a casino have a formal program?
  4. Is there a standard or "pro forma" written program that a casino can use?
  5. What things should be considered when analyzing a casino's risk for money laundering?
  6. Are there any items that must be included in the casino's AML program?
  7. If a tribe has several casinos, is each casino required to have a separate AML program?
  8. What are the reporting, recordkeeping, and disclosure requirements for casinos?