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Beyond the SAR-C: Best Practices for Gaming Companies to "Know Their Customer" and Avoid Organizational Money Laundering Liability in the Post-Sands Climate

UNLV Gaming Law Journal

In this article, Joseph Rillotta summarizes the events giving rise to the Las Vegas Sands Corporation (Sands) criminal investigation, the non-prosecution agreement that Sands entered into with the government to resolve that matter, and the subsequent statements of prosecutors and regulators concerning their broad anti-money laundering (AML) enforcement efforts. Rillotta suggests a series of measures gaming companies may consider putting in place, in light of the Sands case and other recent developments, in order to strengthen their compliance efforts and minimize their exposure under the federal money laundering laws.