As a result of the previously reported reimposition of United States nuclear-related sanctions against Iran, on October 11, 2018, the Financial Crimes Enforcement Network (FinCEN) released an Advisory that provides casinos, and other financial institutions, updated guidance for identifying possible Iranian related criminal transactions.

FinCEN warns that the “Iranian regime, and its officials will increase their efforts to evade U.S. sanctions to fund malign activities and secure hard currency for the Government of Iran….” Further, casinos are encouraged, as part of their federally mandated Anti-Money Laundering (AML) compliance program, to “take reasonable, risk-based steps to identify and limit any exposure they may have to [sanctioned Iranian] funds.”

Almost universally, a casino’s risk-based approach to AML compliance will dictate heightened scrutiny and enhanced due diligence of any and all transactions connected to a bank, business or individual with Iranian ties. With FinCEN’s Advisory in mind, it may be time for casinos to re-visit their unique risk profile to ensure appropriate policies, procedures and processes are instituted to achieve compliance under the Bank Secrecy Act and the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010.