Casino Customer Identity Verification and Tracking

Casino customer identity verification and tracking presents many challenges as well as opportunities for improvement. While casinos are not required to have a Customer Identification Program (CIP), they must address money-laundering and tax reporting beyond certain transaction amounts with a proper method of identity verification and gaming activity reporting. The casinos also like to track player activity for their players club and loyalty reward programs, however, the current player tracking with a conventional players card is not efficient as we will discuss in this article.

Casino Customer Identity Verification and Tracking

Casino Customer Identity Verification and Tracking – The Problem

Casinos encourage their customers to enroll in their players card program to receive rewards for time and money they spend in their casinos. This strategy is a win-win for both the casinos and their customers. When players identify themselves with their players card at the slot machines or table games, casinos are able to track how much time and money they spend during their visit so their marketing team can target valuable players and bring them back. Players also receive rewards for allowing casinos to track their gaming activities. One of the problems with anti money laundering compliance and KYC in the gaming industry is that this is currently a voluntary process and players don’t have to use players card when playing games. Another problem is that customers who would like to enroll in a players reward program must often stand in long lines to enroll or even to request a new card if they are enrolled but forgot to bring it to the casino. This process is flawed as customers spending time in lines to speak with a host is lost revenue for the casinos as players can play instead of standing in lines. Secondly, casinos spend huge amount of money on staff and equipment to print the players cards. Face recognition technology is widely available and can help casinos identify and track all players efficiently at all times. Let’s discuss a recent regulatory change related to casino customer identity verification and tracking and then face recognition opportunity.

The New FinCEN Rule for Casinos: Non-Documentary Identification

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued an “exception rule” to casinos that will allow casinos and clubs to rely on ‘non-documentary identification verification’ for casino customers. The new rule took effect in October 2021, and provides regulatory relief called “exceptive relief” which some consider to be an essential step in the right direction for casinos and their customers.

The casinos can identify their customers via various methods such as examining a document like an unexpired driver’s license, passport, or another government-issued identification card, including a military ID. The casinos can also rely on ‘non-documentary means’ such as leveraging personal data verification systems. In the past, FinCEN had provided relief from these regulations to allow financial institutions to obtain and retain information from various sources to verify customer identities without requiring source documents for customers who opened accounts under $500 million in the average daily balance of funds held during each business day over a period of six months.

The new rule provides guidance around acceptable documentation that casinos must retain about their customers when they do not require an individual’s address, and validation of supplemental information with commercially available databases maintained by private companies for these purposes.

The FinCEN provides this regulatory relief to casinos and their customers to help combat money laundering activities that are believed to be occurring within the casino industry. While there is no evidence that documented transactions have been linked directly with criminal activity, this was a necessary step identified in the due diligence made by FinCEN’s new leadership.

The new rule would provide a great deal of relief to casinos and their customers. It will give them the flexibility to continue being proactive from a compliance standpoint while providing an opportunity for less burdensome regulatory requirements that can help save money, time, and resources. This applies only when dependable methods are used by casinos when trying to identify their customer base along with having an effective oversight program in place. With over 100 billion dollars worth of bets placed annually across 100 different US-based gaming facilities, there needs to be some degree of flexibility in identifying customers. This is what this new rule will provide, along with the proper guidance needed for casinos and their customers to comply.

Face Recognition and Artificial Intelligence (AI) for Activity Tracking

“Face recognition” is a fast-growing and widely used biometric authentication technology which can be used for casino customer identification, age verification, and players’ activity tracking at game tables and machines, allowing for player tracking across multiple casino properties without presenting players’ card identification or signing up for multiple rewards program each time they visit a casino to play. This will streamline the process to reduce cost and increase revenue for the casinos.

Artificial Intelligence (AI) is a computer science field that emphasizes the creation of intelligent machines capable of reasoning, learning, and solving problems independently. AI can be used in age verification process by using machine learning algorithms that allow computers to learn on their own without being programmed with specific rules/features, which would otherwise limit its capabilities when it comes to identifying individuals based on facial characteristics such as nose shape, eyes spacing, etc. just like humans do naturally when looking at another person’s face. In this case, instead of human processing power doing the work, we rely on AI to detect more accurate results under various conditions. This technology is already being used in airports, retail stores, and even concerts to detect potentially dangerous persons or objects that may threaten public safety.

AI with the power of big data behind it, can make it possible for casinos to better manage their risk profile and provide more opportunities for predictive analysis enhancements with advanced tools. This will lead to improved decision-making capabilities when looking at things like “who” should be targeted by marketing campaigns while also providing casino managers insights on what types of games/slot machines are most popular among various demographic groups based on age, gender, etc. Casino owners can feed this information into customer relationship management (CRM) systems, so dealers can provide more personalized experiences.

Additionally, using AI can help identify money laundering activities within the industry. This will help casino management and law enforcement agencies better identify suspicious activities and allow casinos to monitor and improve their compliance efforts or increase revenue.


In conclusion, the casino customer identity verification and tracking process can be automated and improved. The main problems with the current process is that not all customers are tracked at all times and the process of issuing players cards to customers who ask for it is not cost effective or efficient.

The benefits of using face recognition technology are twofold: automated identity and age verification at table games and slot machines, and, eliminating players card and tracking players across multiple casino properties with their consent at all times without presenting identification card or signing up for a rewards program each time they play. This will streamline the process, reduce the cost of printing cards, eliminate player time wasted in players’ card lines, thus increasing playtime and revenue generated by the casinos.