Status: Primary Source Regulatory Mapping
Asset ID: USA-NJ-AML
Jurisdiction Code: USA-NJ
Supervisory Model: Bifurcated Federal Structure
1. Statutory Framework
Core Gambling Legislation
Casino Control Act
N.J.S.A. 5:12-1 et seq.
New Jersey Administrative Code
N.J.A.C. 13:69 et seq.
Anti-Money Laundering Legal Basis
Bank Secrecy Act of 1970 (31 U.S.C. § 5311 et seq.)
USA PATRIOT Act of 2001
31 CFR Chapter X
31 CFR Part 1021 – Rules for Casinos and Card Clubs
Casinos meeting the statutory revenue threshold are classified as “financial institutions” under 31 U.S.C. § 5312(a)(2)(X) and are subject to federal anti-money laundering and counter-terrorist financing obligations under the Bank Secrecy Act framework.
2. Primary Gambling Supervisor
Regulatory Authority: New Jersey Division of Gaming Enforcement (DGE)
Legal Basis: Casino Control Act
Adjudicatory Authority: New Jersey Casino Control Commission (CCC)
Core Regulatory Instruments
- Casino Control Act provisions
- N.J.A.C. 13:69 regulatory framework
- Internal control submission requirements
- Licensing investigations and suitability determinations
The DGE exercises state-level gambling supervision over licensed casino and online gaming operators in New Jersey.
3. AML Oversight Ecosystem
- Financial Crimes Enforcement Network (FinCEN) – Administrator of the Bank Secrecy Act
- Internal Revenue Service (IRS) – Delegated authority for Title 31 compliance examinations of casinos
- U.S. Department of Justice – Criminal enforcement of federal AML statutes
AML supervision of casino operators is exercised at the federal level under the Bank Secrecy Act framework and operates independently of state gambling regulatory supervision.
4. Reporting Architecture
Internal Compliance Controls
- Written AML program pursuant to 31 CFR § 1021.210
- Designation of a compliance officer
- Independent testing for compliance
- Employee training programs
Suspicious Activity Reporting
SAR-C filing requirement under 31 CFR § 1021.320 (transactions involving $5,000 or more)
Currency Transaction Reporting
CTR-C filing requirement under 31 CFR § 1021.311 (cash transactions exceeding $10,000 in a single gaming day)
Reporting Channel
Electronic filing through the FinCEN BSA E-Filing System
Federal reporting obligations are independent of state gambling regulatory reporting.
5. Supervisory Model Classification
- State-level gambling supervision under the Casino Control Act (DGE / CCC)
- Federal AML supervision under the Bank Secrecy Act (FinCEN / IRS)
Banking supervision is exercised separately under federal financial regulatory authorities and is not administered by state gambling regulators.
6. Public Enforcement Framework
Federal
- Civil money penalties under 31 U.S.C. § 5321
- Criminal liability under 31 U.S.C. § 5322
Enforcement actions are published by the U.S. Department of the Treasury and FinCEN.
State
- Administrative sanctions under the Casino Control Act
- License suspension or revocation
State enforcement actions are published through official New Jersey Division of Gaming Enforcement communications.
There is no single unified statutory cap applicable across federal and state enforcement layers; penalties arise under their respective statutory frameworks.
7. Primary Source Registry
- Casino Control Act (N.J.S.A. 5:12-1 et seq.)
- New Jersey Administrative Code (N.J.A.C. 13:69)
- Bank Secrecy Act (31 U.S.C. § 5311 et seq.)
- 31 U.S.C. § 5312(a)(2)(X)
- 31 CFR Part 1021
- 31 U.S.C. §§ 5321–5322
- FinCEN BSA E-Filing System
8. Data Classification Notice
This page contains primary-source statutory and supervisory references only. No analytical scoring, interpretative grading, or risk classification is included in this data layer.