Status: Primary Source Regulatory Mapping
Jurisdiction Code: USA-PA
Supervisory Model: Bifurcated Federal Structure

1. Statutory Framework

Core Gambling Legislation (State Level)

Pennsylvania Race Horse Development and Gaming Act
4 Pa.C.S. Part II

Act 42 of 2017 (Pennsylvania Gaming Expansion Act)

58 Pa. Code — Pennsylvania Gaming Control Board Regulations

Anti-Money Laundering Legal Basis (Federal Level)

Bank Secrecy Act of 1970 (31 U.S.C. § 5311 et seq.)
31 U.S.C. § 5312(a)(2)(X)
31 CFR § 1010.100(t) — Definition of “Casino”
31 CFR Chapter X
31 CFR Part 1021 — Rules for Casinos and Card Clubs

Casinos with gross annual gaming revenue in excess of $1,000,000 are classified as “financial institutions” under 31 U.S.C. § 5312(a)(2)(X), as implemented by 31 CFR § 1010.100(t), 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: Pennsylvania Gaming Control Board (PGCB)

Legal Basis: 4 Pa.C.S. § 1201 et seq.

Core Regulatory Instruments

• Pennsylvania Race Horse Development and Gaming Act
• 58 Pa. Code (PGCB Regulations)
• Licensing investigations and suitability determinations
• Internal control submission and approval requirements

The Pennsylvania Gaming Control Board exercises state-level regulatory authority over licensed casino and online gaming operators within Pennsylvania.

3. AML Oversight Ecosystem

• Financial Crimes Enforcement Network (FinCEN) — Administrator of the Bank Secrecy Act
• Internal Revenue Service (IRS) — Delegated authority to conduct Title 31 compliance examinations of casinos
• U.S. Department of Justice (DOJ) — Criminal enforcement of federal AML statutes

Under 31 CFR § 1021.210, casino operators must implement a written AML program, including internal controls, independent testing, employee training, and designation of a compliance officer.

Federal AML supervision 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
• Employee training

Suspicious Activity Reporting

SAR-C filing requirement under 31 CFR § 1021.320

Triggering threshold: Transactions involving or aggregating ≥ $5,000

Reports filed electronically through the FinCEN BSA E-Filing System

Currency Transaction Reporting

CTR-C filing requirement under 31 CFR § 1021.311

Triggering threshold: Cash transactions > $10,000 in a single gaming day

Federal reporting obligations apply uniformly across states and are not displaced by state gambling regulatory reporting requirements.

5. Supervisory Model Classification

• State-level gambling supervision under the Pennsylvania Gaming Control Board
• Federal AML supervision under the Bank Secrecy Act (FinCEN / IRS)

Banking supervision of financial institutions interacting with casino operators is conducted by federal banking regulators and is institutionally separate from 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

Federal enforcement actions are published by the U.S. Department of the Treasury and FinCEN.

State

• Administrative sanctions under 4 Pa.C.S.
• License suspension or revocation

State enforcement actions are published through official Pennsylvania Gaming Control Board communications.

There is no unified statutory maximum cap applicable across federal and state enforcement layers; penalties arise under their respective statutory frameworks.

7. Primary Source Registry

• Pennsylvania Race Horse Development and Gaming Act (4 Pa.C.S. Part II)
• Act 42 of 2017
• 58 Pa. Code (Pennsylvania Gaming Control Board Regulations)
• Bank Secrecy Act (31 U.S.C. § 5311 et seq.)
• 31 U.S.C. § 5312(a)(2)(X)
• 31 CFR § 1010.100(t)
• 31 CFR Part 1021
• 31 U.S.C. §§ 5321–5322

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.