As the gaming industry prepares to come together in Las Vegas for the annual BSA/AML Gaming Conference, there is no better time for AML professionals, regulators, law enforcement, and industry leaders to share what they are seeing and collectively contemplate the threats confronting our industry.

The financial crime environment surrounding gaming is changing rapidly. Organized crime is global, networked and sophisticated, and the financial infrastructure supporting it spans industries, institutions, and borders. For those of us responsible for protecting the integrity of gaming and the broader financial system, understanding that changing landscape has never been more important.

The U.S. government has made the urgency of these threats increasingly clear.

In February 2025, the Department of Justice (DOJ) directed its resources toward the “total elimination” of cartels and transnational criminal organizations. DOJ has since identified complex money laundering schemes, including Chinese Money Laundering Networks (CMLN), as an enforcement priority and has placed increasing emphasis on disrupting the financial infrastructure that allows transnational criminal organizations to operate.

Recent government actions demonstrate how interconnected these threats have become.

In August, a member of a CMLN was sentenced to 15 years in federal prison for his role in an organization that laundered more than $92 million in illicit funds, including drug-trafficking proceeds. DOJ described CMLNs as a key enabler of Mexican cartels.

Gaming has also appeared directly within this evolving threat environment.

The U.S. Treasury has targeted transnational criminal organizations with gaming interests spanning multiple countries. In one action, Treasury and the Government of Mexico targeted an organized crime group that authorities said used casinos and restaurants to launder narcotics-trafficking proceeds, with designated gaming-related entities extending beyond Mexico into Canada and Europe.  

More recently, Treasury sanctioned casinos associated with Cartel del Noreste, a U.S.-designated Foreign Terrorist Organization, including a casino Treasury said was used to launder illicit proceeds through gaming operations.

These actions are part of a much larger financial crime picture.

In 2025, FinCEN provided an extraordinary window into its scale. Its analysis identified 137,153 Bank Secrecy Act reports associated with suspected Chinese Money Laundering Network activity between 2020 and 2024, representing approximately $312 billion in suspicious transactions.

Taken together, these developments illustrate an important shift in the threat landscape. For the gaming industry, it is vital that AML compliance programs understand these networks and the role we can play in identifying and disrupting them.

A Global and Networked Threat

Chinese Money Laundering Networks provide a particularly important example of how modern financial crime can operate.

Drug trafficking organizations can accumulate enormous amounts of illicit cash in the United States that they need to convert into usable value. At the same time, individuals with legitimate wealth in China may seek access to funds outside the country because of capital controls.

Professional laundering networks can connect those two needs.

An individual seeking access to funds outside China may deal only with an unlicensed money transmitter or underground banking intermediary, while the drug-trafficking organization deals with another part of the same network. The intermediary can connect the two without the parties ever meeting, communicating, or knowing who sits on the other side.

Through underground banking, intermediaries, mirror transactions, trade-based money laundering and other settlement mechanisms, value can move between parties without the underlying funds necessarily following the same path.

The result is a network in which criminal proceeds, customers, intermediaries, businesses and financial institutions can be connected across countries, while no individual transaction necessarily reveals the broader structure.

We can see variations of these mechanisms appearing around the world.

In Australia, major regulatory and enforcement matters involving the regulated casino sector exposed underground banking, opaque third-party arrangements and cross-border financial intermediaries. Suncity (a junket operator) and its former chairman, Alvin Chau, became central figures in investigations involving gaming markets across the Asia-Pacific region. Chau was ultimately convicted in Macau of offenses including criminal association, illegal gambling, and aggravated money laundering, and sentenced to 18 years in prison.

In Canada, the Cullen Commission documented another variation of the model. Individuals seeking Canadian currency for gambling and other purposes could obtain cash through facilitators while equivalent value was settled elsewhere, creating a mechanism through which criminal organizations could dispose of illicit cash.

We have seen these risks surface in U.S. gaming enforcement actions as well. Federal authorities have documented the use of unlicensed money transmitters, third-party intermediaries, and international accounts to provide casino patrons access to funds outside conventional financial channels.

Beyond gaming, U.S. authorities continue to document criminal networks using bulk cash, foreign accounts, mirror transfers, shell companies, cryptocurrency and trade-based money laundering to move value across the United States and internationally.

The specific methods vary. The broader pattern is familiar: people, money and value move across institutions and borders, while individual participants in the financial system may see only a fragment of the overall activity.

Gaming Has Confronted Organized Crime Before

The gaming industry has confronted organized crime before, and the regulatory framework that exists today was shaped by that experience. From the middle of the twentieth century through the 1970s and 1980s, operators, regulators, and law enforcement, particularly in Nevada, worked to remove traditional organized crime from regulated gaming. The resulting emphasis on licensing, suitability, ownership, control, and sources of investment helped establish the integrity and legitimacy that allowed the industry to grow.

That effort was enormously successful, deserves recognition, and offers a useful frame for the challenge today. The historic focus was heavily on who owned, controlled, financed, and influenced a gaming business. Today's financial crime challenge increasingly requires us to understand who is using gaming services, how money and value are moving, and whether activity visible at one property is connected to activity elsewhere.

As the threat has become more global and networked, our visibility must become broader and more connected.

What We Are Seeing in the Data

What we are seeing in our data reinforces this broader shift.

Across our national dataset, we looked at patrons based on the amount of money they brought into the casino.

The highest-value patrons (those bringing the most money into the casino) accounted for only 19% of identified suspicious activity and less than a quarter of the associated dollar value.

Very little was concentrated at the other end of the spectrum. The lowest-spending patrons accounted for less than 2% of identified suspicious activity and associated dollar value.

Instead, the activity was overwhelmingly concentrated in between. The middle spenders of the patron population accounted for 78% of identified suspicious activity and 74% of the associated dollar value involving many thousands of patrons.  

We are also seeing significant movement across properties. Our data reveals that approximately 1 in 5 patrons play at multiple properties, and almost two-thirds of patrons associated with identified suspicious activity played across multiple properties.

That means patrons associated with identified suspicious activity were nearly four times more likely to play across multiple properties.

These trends reinforce the broader shift in the global threat environment being communicated by governments and documented in recent enforcement actions. The emerging picture is increasingly one of networked activity involving large numbers of people, transactions, and billions of dollars moving across institutions and jurisdictions.

Additionally, these trends indicate that traditional gaming AML programs that are property-focused and use spending as a proxy for risk are mis-calibrated. Patrons associated with suspicious activity play across properties nearly two-thirds of the time, while the overwhelming majority of identified suspicious activity involves thousands of players in the middle tier of spend, where few individual patrons look remarkable but the aggregate financial activity reaches into the billions of dollars.

Monitoring concentrated on the highest-spending patrons therefore concentrates resources where suspicious activity is thinnest, while the group that accounts for the overwhelming majority of identified activity receives less scrutiny. The lesson from our data is pointed: an AML program that treats spending as a proxy for risk is not only detecting less; it is tuned not to look where the vast majority of suspicious activity is occurring.

One property sees an event. A network can see the pattern.

This is a structural limitation: a property can investigate and report what it sees while another property, a bank, a regulator, or a government agency holds another part of the same story. Everyone can be doing their job extraordinarily well and still see only one piece of a much larger network.

As the organizations confronting the financial system become more networked, understanding those connections becomes essential.

From Data to Intelligence

We are already seeing important first steps in this direction.

Gaming operators are investing in technology that brings together customer, transaction, and risk information to provide greater visibility into financial crime. Some of the largest commercial and tribal gaming organizations in the United States were early supporters of these capabilities, often with direct involvement from CEOs, board members, and senior executives.  

Kinectify's own history reflects that commitment: more than $26 million has been put to work building and supporting our technology, with the majority of invested capital coming from gaming executives, operators, Tribal Nations, and industry suppliers. That level of support speaks to how seriously this industry takes its responsibility and the opportunity to build better tools to protect its integrity.

These developments represent the beginning of a much larger opportunity. As these capabilities evolve, the gaming industry is well positioned to modernize its risk management infrastructure, contribute valuable intelligence to the broader fight against financial crime, and strengthen the integrity of both the gaming industry and the U.S. financial system.

Networked threats require networked visibility

As the global threat landscape has changed, so too have responses to this new reality.  

Financial regulators around the world are increasingly developing public-private partnerships that bring government and industry together around financial intelligence. FATF has identified at least 84 public-private financial crime partnerships globally. Many of these share strategic intelligence, suspicious indicators, typologies, and operational intelligence such as case intelligence and customer due diligence information.  

Australia has the Fintel Alliance, the United Kingdom has JMLIT, and Hong Kong has FMLIT.

These programs differ in structure, authority, and membership, yet they share a practical understanding of the problem: each participant sees a different part of the financial crime picture. Operators understand their patrons, transactions, source-of-funds inquiries, and operational context. State and tribal regulators can identify issues emerging across licensees and markets. FinCEN and law enforcement can connect activity across industries, jurisdictions, and national borders.

Under traditional regulatory and enforcement models, activity occurs, investigations and examinations follow, and significant enforcement actions may arrive years after the underlying conduct.

Some jurisdictions are moving toward more collaborative models in which government and industry share appropriate intelligence, identify emerging signals and patterns, better understand the threat, adapt controls, and intervene earlier.

The goal is more actionable intelligence, greater cooperation, and earlier identification of risk. Some of these partnerships are also developing technology infrastructure that can reduce the operational burden on participants and allow intelligence to move closer to real time.

Intelligence is key

We have more data and more powerful analytical capabilities than ever before. Advances in analytics and intelligence technology are giving operators, regulators, and law enforcement new ways to turn that data into intelligence and better understand the networks behind the activity.

The threats are becoming more connected. Our ability to understand them must become more connected as well.

That is a conversation I look forward to continuing with many of you at the BSA/AML Gaming Conference in Las Vegas.