How Casinos Should Prepare for FinCEN’s 2026 AML/CFT Overhaul

FinCEN’s April 2026 proposal would significantly expand what casinos must demonstrate to maintain an effective Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) program under 31 CFR Part 1021. The Notice of Proposed Rulemaking (NPRM) introduces explicit risk‑assessment process requirements, integrates National Priorities into program design, and adds new governance expectations.... By: Ballard Spahr LLP