November 25, 2019

In this article, Jenner & Block Partners Reid J. Schar and Wade A. Thomson and Associate E.K. McWilliams analyze an August speech by the director of the Financial Crimes Enforcement Network, an arm of the US Department of the Treasury.  In his speech, Kenneth A. Blanco indicated that FinCEN is monitoring casinos to ensure that they live up to their reporting obligations under the Bank Secrecy Act (BSA).  Mr. Blanco’s remarks also noted FinCEN’s focus on the money laundering risks associated with cryptocurrency and sports betting.  “Blanco’s remarks in Las Vegas affirm FinCEN’s commitment to enforcing the BSA on casinos that deal in cryptocurrency – regardless of the scale of the operation, and regardless of whether the casino accepts cryptocurrency ‘from customers either on location or through mobile applications,’” the authors write.