Las Vegas hosted one of the most consequential BSA/AML Gaming Conferences in recent memory.

Federal authorities repeatedly emphasized a financial crime threat landscape that has grown more complex, sophisticated, and networked. Drug cartels, organized fraud, cybercrime, professional money laundering organizations, and Chinese money laundering networks featured prominently throughout the conference.

One point was particularly important for the gaming industry: the federal government emphasized that criminal networks are increasingly turning to the gaming industry to move and launder illicit proceeds.

That concern extends well beyond the conference.

The U.S. Treasury's 2026 National Money Laundering Risk Assessment found that money laundering risks across gaming in the United States continue to grow and evolve. Treasury identified drug trafficking, organized crime, foreign criminal activity and illegal gambling among the sources of illicit proceeds moving through the sector. It also highlighted vulnerabilities involving traditional casinos, sports betting, sweepstakes, illegal gambling, and other parts of the expanding gaming ecosystem.

FATF reached similar conclusions from a global perspective. Its recent work on the risks of gaming and gambling examines an ecosystem that has become increasingly digital, cross-border, and interconnected. FATF identified links between criminal abuse of gaming and cyber-enabled fraud, organized crime, and professional money laundering networks, along with gaps in regulatory coverage that criminals can exploit.

These are significant developments for our industry.

Follow the Money

The human consequences behind this activity are staggering.

During the conference, Treasury highlighted that more than 1,000 Americans die per week from drug overdoses and that drug cartels and professional money laundering networks are profiting from this drug trade.  

Fraud networks are also targeting Americans at enormous scale. Treasury discussed organized fraud as a national security concern and criminal networks using increasingly sophisticated technology and financial infrastructure to target Americans and move the resulting proceeds.

All of this activity generates vast amounts of money that has to move.

Professional money laundering organizations provide the infrastructure to move and disguise those proceeds across people, institutions, industries, and borders. Chinese money laundering networks have become a particular concern because of their role laundering drug proceeds and their use of the gaming sector.

Gaming is just one part of that financial system. And the scale of what gaming AML professionals are already identifying is substantial.

The Scale Is Easy to Underestimate

From 2020 through 2024, gaming licensees across the United States filed nearly 300,000  Suspicious Activity Reports (SARs), according to FinCEN's publicly available SAR filing trends.

Our own U.S. data provides another view of the activity underneath those reports.

Across the properties we analyzed, tens of thousands of patrons were associated with identified suspicious activity, with amounts averaging roughly $200,000 to $400,000 per suspicious activity event.

Individually, many of these patrons look unremarkable, but collectively, the activity reaches into the billions of dollars.

And the risk isn't concentrated exclusively among the industry's biggest players.

In our national analysis, the middle of the customer population accounted for 78% of identified suspicious activity and 74% of the associated dollar value. Nearly two-thirds of patrons associated with identified suspicious activity played across multiple properties. Those patrons were nearly four times more likely to play across multiple properties than the broader customer population.

This is clearly a big data problem.

A patron may look unremarkable at one property. A transaction may look unremarkable on its own. Activity at another property may provide another piece. A financial institution may hold another. Law enforcement may have another.

The pattern emerges when those pieces begin coming together.

Think in Networks

That idea came through repeatedly in Las Vegas.

IRS and Law enforcement discussions focused heavily on connected networks and emphasized the importance of thinking in networks and to understand the context behind the individual transactions. In sum, the message was that individual reports provide data points, but connecting those events can reveal millions of dollars in activity and relationships that are difficult to identify transaction by transaction.

BSA reporting plays an important role in that process.

IRS representatives highlighted the critical role BSA data plays in investigations, noting that 94% of IRS cases were searched against BSA data during the prior year.

Think about that alongside the volume of financial intelligence generated by the gaming industry.

The information collected by AML professionals doesn't simply end with a filing. It can become part of a much larger body of intelligence that helps investigators connect people, money, businesses, and criminal organizations.

That makes the quality of the information important. It also makes our ability to connect information increasingly important.

Criminal organizations already operate as networks. Our visibility needs to catch up.

AML Is Modernizing

One of the most encouraging themes in Las Vegas was how much movement is beginning to take place.

The message was remarkably consistent across all levels of government including multiple federal departments, state control boards, and gaming operators: modernization is underway and AI has a critical role to play.  

Treasury discussed efforts to modernize the U.S. AML framework around effectiveness and risk. The emphasis was on understanding where risk is highest, concentrating resources against those risks, strengthening enterprise-wide risk management, improving information sharing, and using technology more effectively.

One of the more meaningful messages at the state level was from Nevada, which characterized recent efforts as significant and a strong first step, and acknowledged that there is more work to be done, the effort is continuous, and other state authorities appeared to match that tone.  

That's important.

The threat landscape isn't standing still. Criminal networks are changing. Technology is changing. Gaming is changing. Regulation and risk management have to continue evolving with them.

Information Sharing Matters

Information sharing was a major theme throughout the conference. Treasury emphasized the need to connect information across institutions to identify illicit networks that no single organization can see on its own.

Nevada provided a strong example, highlighting its innovative 314(b) information-sharing pilot, with gaming operators describing the success of the initiative.

No institution sees the entire network. As threats become more connected, our ability to understand them must become more connected as well.

We Need a Level Playing Field

There is another challenge that was heavily discussed: Financial crime doesn't organize itself around regulatory boundaries.

FATF's latest work identifies the large amount of gaming operators not covered by AML regulation and the risk that exposes.  

The US government raised similar concerns about the patchwork of regulation across different parts of gaming and emphasized that we are only as strong as our weakest link. The government explained that the purpose of FATF is to encourage a level playing field globally since organized crime operators globally.  

This matters as gaming continues to expand.

In most US jurisdictions today, a customer can engage in substantially similar gaming activity with vastly different financial crime oversight depending on the venue or product: slot routes, online gaming, daily fantasy sports products, predictions markets, and so forth.  

Criminal networks look for those gaps.

Closing them requires us to understand where the risks exist and make sure our visibility and controls evolve alongside the industry.

Today's War Requires Today's Technology

The scale and complexity of today's threat landscape make modern technology essential.  

There is simply too much information across customers, transactions, properties, and products to connect manually. We’re operating on a scale of hundreds of thousands of BSA reports. Billions of dollars. Tens of thousands of patrons. Networks operating across institutions and borders.

Federal authorities were unusually direct: criminals are already using advanced technology and it’s imperative we use innovative tools and methods too including artificial intelligence, digital identity, and better connected data visibility.  

Significant discussion revolved around the need for the risk management calculus to structurally change. AML programs cannot remain dependent on 90%+ false-alert rates or analysts spending most of their time manually processing data. Risk-based AML requires better technology.  

We need to tool up to fight today's war.

Strong Risk Management Supports a Strong Gaming Industry

Gaming is an extraordinary entertainment industry that creates jobs, drives tourism, generates economic activity, and continues to innovate.

State gaming regulators made an important point at the conference: strong regulatory frameworks help support the industry's growth and success. The same is true of financial crime risk management.

As gaming becomes larger, more digital, and more interconnected, effective risk management protects customers, communities, operators, and the integrity of the industry while providing a strong foundation for continued growth.

Continuing the Modernization Cycle

Kinectify will continue investing heavily in this modernization—building intelligent technology, expanding data and intelligence capabilities, and getting better tools into the hands of AML professionals.

We will also continue supporting training and forums like the BSA/AML Gaming Conference that bring operators together with federal authorities, state and tribal regulators, and law enforcement.

Government identifies emerging threats. Operators see those threats in real-world activity. Technology helps AML professionals identify and understand them. Better information flows back to government and law enforcement, strengthening our collective understanding of the threat.

That cycle must continue as both financial crime and gaming evolve. Kinectify is committed to helping the industry meet that challenge.

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