Key takeaways
- Tribal casinos must maintain a risk-based AML program that includes transaction monitoring, customer due diligence, reporting, recordkeeping and employee training.
- Casinos must accurately identify customers, file CTRs for cash transactions exceeding $10,000, submit SARs for suspicious activity involving $5,000 or more and use transaction monitoring tools to detect unusual patterns and potential money laundering risks.
- Staff across gaming, cage, surveillance, security, marketing and compliance functions should receive role-specific AML training and understand how to recognize, document and escalate suspicious activity.
- Regular risk assessments, ongoing program reviews, accurate recordkeeping, updated policies, dedicated compliance oversight and investments in AML technology help tribal casinos demonstrate compliance and adapt to evolving regulatory expectations.
Preventing money laundering needs to be a priority for tribal casinos. A strong Title 31/anti-money laundering (AML) compliance program helps casinos meet federal requirements, detect suspicious activity and demonstrate to regulators that effective controls are in place
Keep reading to learn more about Title/31 requirements and how tribal casinos can improve their compliance posture.
What is Title 31?
Title 31 is the anti-money laundering provisions of the Bank Secrecy Act (BSA) that apply to casinos and other financial institutions. The regulations are designed to prevent money laundering at legitimate businesses and to help law enforcement identify financial crimes. Tribal casinos are required to maintain a risk-based AML program that includes customer monitoring, reporting, recordkeeping and employee training.
For tribal casinos, Title 31 compliance is about more than filing reports. Regulators increasingly focus on whether a casino’s overall AML program effectively identifies, assesses and mitigates financial crime. This includes governance, risk assessments, transaction monitoring, customer due diligence and documentation that demonstrates the program is operating as intended.
Title 31 casino requirements
To comply with Title 31/AML, casinos need processes for monitoring transactions, maintaining records, identifying customers and reporting potentially suspicious activity.
Title 31 reporting requirements
A primary obligation under Title 31 is filing Currency Transaction Reports (CTRs). A CTR must be completed for every cash-in or cash-out activity that exceeds $10,000. When doing a CTR, casinos need to see a government-issued ID and collect customer information such as name, physical address and Social Security number.
Casinos are also required to file Suspicious Activity Reports (SARs) for transactions involving at least $5,000 when suspicious activity is identified. Suspicious activity can include structuring transactions to avoid reporting thresholds, chip passing, unusual transaction patterns or other behavior that may indicate money laundering or financial crime.
Multiple Transaction Logs (MTLs) are commonly used to track transactions of $3,000 or more, helping casinos identify patterns before reporting thresholds are reached.
To support reporting obligations, casinos should implement processes and technology that monitor and aggregate transactions across gaming operations. Many organizations use specialized AML systems to track activity, identify reporting thresholds and alert employees when customer information must be collected.
AML recordkeeping requirements
Casinos should maintain all documentation used to support CTRs, SARs and related investigations. Be sure your records are complete, accurate and readily available for review. Supporting documentation may include MTLs, Monetary Instrument Logs (MILs), surveillance reports, system-generated transaction reports, customer due diligence files and internal investigation records. Maintaining organized records allows casinos to quickly produce both reports and supporting evidence during examinations.
AML records should be retained for at least five years.
Title 31 customer identification and due diligence
To effectively spot red flags, casinos need to know who is gambling at their location. When suspicious activity is identified, casinos should conduct additional research.
Know your customer (KYC) activities may include:
- Negative news searches
- Open-source research
- Reviewing social media profiles
- Using investigative or public records software
- Promoting players’ cards that help casinos capture more information on their patrons.
- Interactions with higher-tier clientele.
Casinos should pay particular attention to patrons who repeatedly conduct transactions just below reporting thresholds or who exhibit unusual transaction timing patterns, such as cashing in or out just before or after the gaming day turns.
Also, pay close attention to patrons whose employment or financial status doesn’t align with the amount they are gambling. An unemployed patron gambling thousands of dollars should raise suspicion.
Title 31 training requirements for casino employees
Staff members are often the first line of defense in identifying suspicious activity and ensuring reporting requirements are met, making training a key component of Title 31/AML compliance.
Who needs Title 31 training?
Your casino’s staff should be required to go through Title 31 training. Employees working in cage operations, table games, slots, security, surveillance, accounting and compliance all play important roles in preventing money laundering. Marketing teams, casino hosts and player development personnel should also receive training because of their direct interactions with patrons.
What should Title 31 training cover?
Training should be tailored to each employee’s role. Personnel involved in transaction processing may require detailed instruction on CTRs, SARs, customer identification requirements and reporting thresholds. Others may need a stronger focus on recognizing suspicious behavior and documenting concerns.
Regardless of role, employees should understand:
- Customer identification requirements
- CTR and SAR obligations
- Indicators of suspicious activity
- Internal reporting and escalation procedures
- Their responsibilities within the AML program
How often should casino employees receive Title 31 training?
AML training should be part of the onboarding process for all new workers. We recommend refresher training be provided at least annually. Training may also be necessary when employees transfer into new roles with different AML responsibilities, where they may be more front of the house or dealing with cash on a more frequent basis.
If an assessment or investigation reveals deficiencies in your AML program, that could suggest your training also needs to be revamped to better account for the risk at your facility.
How tribal casinos can strengthen Title 31 compliance
Maintaining compliance requires continuous attention and ongoing program improvement. The most effective AML programs continuously monitor risk and changes while combining well-trained personnel, strong controls and investments in technology that make it easier to identify and address risks.
Keep up with changing regulatory requirements
These requirements aren’t static. Title 31/AML rule changes will happen, and regulators are increasingly emphasizing risk-based AML programs, stronger governance, effective suspicious activity monitoring and documented compliance efforts. Designate an AML compliance officer who is responsible for tracking regulatory developments and ensuring your casino adapts its program, policies and training as necessary.
Identify and report suspicious activity
Use every available tool to monitor activity across the gaming floor. Automated alerts, transaction monitoring reports, kiosk activity reviews, chip-tracking processes and surveillance systems can help identify suspicious patterns. Equally important is training employees to recognize and escalate concerns.
Maintain accurate records
Retain all reports, supporting documentation and investigative records. Strong documentation makes it easier to demonstrate compliance during audits and examinations.
Training, training and more training
Your staff, along with your surveillance equipment, are your eyes and ears on the gaming floor. Regular, role-specific training helps employees identify suspicious activity, follow procedures and understand how to escalate concerns.
Conduct a risk assessment to align AML policies with actual casino risk and operations
Tribal casinos each have unique customer demographics, operational procedures, gaming offerings, locations, transaction volumes and regional crime patterns that collectively create a risk profile. Conduct a risk assessment to identify the risks your casino faces and build an AML program to account for those risks and understand how they change with time.
Some factors to consider in your risk assessment include:
- The amount of drug trafficking in your area, including whether your casino operates within or near a High Intensity Drug Trafficking Area (HIDTA)
- The amount of financial crime in your area, including whether your casino operates within or near a High Intensity Financial Crime Area (HIFCA)
- How many large cash players visit your casino
- The size of your gaming room floor
- The games you offer, and which ones get the most play
- The number of anonymous players vs those using player cards
- Any historical trends related to criminal activity at your casino
Policies should be updated accordingly when you add new technology, modify processes or revise controls.
Demonstrate compliance during examinations
IRS examinations often focus on whether a casino can demonstrate that its AML program is functioning effectively. Casinos should be prepared to produce CTRs, SARs, supporting documentation, risk assessments, policies and evidence that monitoring controls are operating as designed.
Invest in the right technology
Modern AML platforms can aggregate data from slot machines, table games, cage transactions and other activities on your floor into a single source, making it easier to identify transaction trends and streamline reporting.
Modern surveillance systems not only provide a real-time view of the entire gaming floor, but also archive footage that can play a major role in AML investigations.
Title 31 compliance checklist for tribal casinos
Download Wipfli’s Title 31 checklist for tribal casinos for actionable steps you can take to evaluate your AML program.
GET YOUR TITLE 31 COMPLIANCE CHECKLIST
FAQs about Title 31 and AML compliance
What is the purpose of Title 31?
The purpose of Title 31 is to help prevent money laundering, terrorist financing and other financial crimes by requiring financial institutions, including casinos, to monitor transactions, maintain records and report qualifying activity. These requirements provide law enforcement and regulators with the information needed to identify potential criminal activity and investigate financial crimes.
For casinos, Title 31 also creates a framework for identifying and mitigating risk. Effective AML programs help protect tribal reputations and reduce regulatory exposure by ensuring suspicious activity is identified and addressed appropriately.
Is Title 31 state or federal?
Title 31 is federal law. The Financial Crimes Enforcement Network (FinCEN) establishes AML requirements under the Bank Secrecy Act, while the IRS is responsible for examinations and enforcement activities. Some state gaming regulatory authorities have issued fines against casinos for AML violations.
What happens if a casino does not comply with Title 31?
Noncompliance with Title 31 can result in corrective action plans and, in some cases, significant monetary penalties. In 2025, Resorts World Las Vegas paid a $10.5 million fine for failing to comply with the AML by allowing known illegal bookmakers to gamble at the property.
Beyond financial penalties, casinos that develop a reputation for noncompliance may face more frequent examinations and heightened oversight. Constantly being under a regulator’s microscope can become burdensome.
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Managing Title 31 compliance can be challenging as regulatory expectations, transaction monitoring requirements and financial crime risks continue to evolve.
At Wipfli, we help tribal casinos strengthen AML programs by performing independent compliance reviews and risk assessments. We can also help write your AML program, provide employee training and monitor your compliance on an ongoing basis. Start a conversation.