Comment from Anonymous
Anonymous AnonymousSupportIndividual
Summary: The commenter is an independent AML compliance consultant for the gaming industry who supports the proposed rule's shift toward risk-based AML programs. They suggest specific refinements to ensure the rule accounts for tribal casino governance, allows for certain types of independent testing, updates outdated risk assessment guidance, and integrates responsible gaming insights.
I appreciate the opportunity to comment on FinCEN’s proposed rule to modernize AML/CFT program requirements. I write as an independent consultant in the gaming industry, specializing in anti-money laundering compliance for casinos. I support FinCEN’s broad goal of shifting toward effective, risk-based AML programs, and I offer the following comments to ensure the final rule adequately accounts for casino contexts and certain practical implementation considerations in the following core areas:
1.Independent Testing – Tribal Casinos and Clarifying “Outside” Independence
2.Independent Testing – The role of advisors in AML Training
3.Risk Assessment – Need for Updated Casino Guidance & Structure
4.Casino-Specific Regulation – Integrating Responsible Gaming
See the attachment for details of these areas