Risk Assessment for Tribal Casinos

The Bank Secrecy Act (BSA) requires that designated “financial institutions” implement and maintain anti-money laundering (AML) programs. Tribal casinos have been designated as financial institutions under the BSA since 1996, and the BSA regulations issued by the Treasury Department in 31 C.F.R. 103.64 prescribe the minimum standards for those programs. All tribal governments conducting or sponsoring gaming activities, whether for one night out of the year or throughout the year, whether in their primary place of operation or at remote sites, must be aware of the federal requirements associated with the Bank Secrecy Act.