Gaming in the Era of COVID-19

The COVID-19 pandemic has created unprecedented social and economic uncertainty.  The hospitality and leisure industry has been among the hardest hit sectors of the global economy and traditional land-based gaming organizations are facing extraordinary financial pressures, including closures and lay-offs.

 Compliance and anti-money laundering professionals in the gaming business who have been laid off will very likely find refuge in other industries – even in these trying economic times – as they have a transferable and in-demand skill set.  When the industry does recover, getting these experienced compliance professionals back will be critical.

 These circumstances result in a need for an enhanced focus on compliance. Gaming organizations should be looking at how they will ensure the continuity of their compliance and anti-money laundering programs in a post COVID-19 world, where they will be faced with tighter financial constraints and potentially less-experienced staff managing those programs.  They may also face an influx of potentially illicit cash that has been lying dormant during the shutdown.

 The current “pause” in operations, as painful as it may be, presents a unique opportunity to prepare for the industry’s grand reopening.  Some of the questions that gaming organizations should be asking themselves in advance of the recovery include:

  • What positions are “mission critical” for continuity of compliance programs and what are the retention strategies for those positions?
  • Are there opportunities to enhance compliance processes and policies?
  • How many former staff are expected to return, how many will be new and how will the organization attract experienced personnel?
  • How will employee training be ramped up prior to opening the gaming floor?
  • What can organizations do to clearly demonstrate to stakeholders – players, employees, shareholders, regulators and the public – that they are ready to open?
  • Is new staff adequately familiar with, and prepared for, regulatory filing requirements?

Gaming organizations that have a footprint in both the online and land-based environments will likely be better positioned to ensure business and compliance program continuity, as the digital side of their business remains open.  But make no mistake: while the industry is reeling from the fallout of the current pandemic, it should use this time to enhance its focus on compliance and anti-money laundering programs.

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