Speaking of anti-money laundering (AML), FinCEN recently published an industry letter to address compliance in the sports betting business. FinCEN confirms that sports books are expected to prevent persons from placing sports wagers on behalf of another, which FinCEN believes is an activity ripe for money laundering. Under Nevada gaming regulations, messenger betting – the act of placing a bet on behalf of another person for compensation – is not permitted and sports books are not allowed to accept wagers from persons who are known or reasonably known to be placing such third-party bets.

Casinos and their sports books must have AML compliance programs to ensure that the proper cash-transaction reports or suspicious activity reports are filed when necessary and to continue to undertake “know-your-customer” measures to prevent money laundering opportunities.