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The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk.
It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.
Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds.
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Under IGRA, gaming is generally prohibited on land taken into trust after 1988 unless it qualifies under specific exceptions. Scotts Valley claims its Vallejo property falls under the “restored lands” exception for federally recognized tribes.
While Interior agreed that Scotts Valley met requirements regarding its modern ties to the area and the timing of the acquisition, the department ultimately concluded the tribe failed to demonstrate a sufficiently significant historical connection to the land.
In court Friday, DOJ attorney Amber Dutton-Bynum argued that Scotts Valley could not meet the high threshold for irreparable harm required to secure an injunction. She maintained that the tribe knowingly chose to invest in the Preview Casino while its gaming status remained uncertain, as reported by Law360. Dutton-Bynum added that the modular buildings could easily be repurposed for non-gaming commercial uses if the prohibition stands.
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The redevelopment was financed by a $455 million loan from New York State, approved in 2023. State officials have projected the project will generate $155 million in annual economic activity once fully operational, along with around $10 million annually in state and local tax revenue.
The redesigned complex features four distinct racing surfaces: a 1½-mile dirt track, two turf courses, and a one-mile Tapeta synthetic track.
The Tapeta surface will be used exclusively for winter racing, allowing Belmont to take over Aqueduct’s former winter schedule as NYRA consolidates its operations at Belmont and Saratoga.