However, this never-ending flow of cash has also made pokies attractive to criminals. Australian gambling operators must, therefore, be aware of the risks of pokies and their anti-money laundering and countering the financing of terrorism (AML/CFT) obligations. 

How are pokies used to launder money? 

Criminals seeking to launder money through pokies often insert large amounts into an EGM (or get a money mule to do it for them) to seem like a genuine player before withdrawing it after little or no actual gameplay. Alternatively, they offer to buy the winnings of legitimate players by exchanging illegal cash for winning credits, typically at a favorable price for the other player. In either case, illegal money is made to look like the legitimate proceeds of gambling, giving criminals an explanation for their source of funds (SoF) if questioned. 

Money laundering through pokies is one sub-type of money laundering through gambling and conforms to the three-stage structure found in other typologies. 

Money mules and pokies 

Money mules are people recruited by criminals to launder money for them by proxy, sometimes knowingly and sometimes not. Money muling is a significant issue in gambling-related money laundering in Australia, with criminals giving mules commissions to layer money through pokies or casinos and using mule bank accounts to obscure the source of their funds further. In November 2024, news stories emerged concerning criminals paying individuals for identity documents so they could set up betting and bank accounts in their name. 

Acknowledging the scale of the problem, in 2024, the Australian Transaction Reports and Analysis Center (AUSTRAC) issued a guide to help firms recognize red flags. Indicators of money laundering in customer behavior applicable to pokies include: 

• Access to more cash than expected for their customer profile profile. 
• Depositing higher values and larger amounts of cash. 
• Transferring cash or gaming tokens to patrons. 
• Obtaining casino disbursement checks for winnings or non-winnings. 
• Occupations such as students or secretaries and directors of recently incorporated companies.

Pokie regulations in Australia

Pokies are found across casinos, pubs, and sports or social clubs across Australia, where their extreme popularity has created serious financial crime risks. In 2022, the New South Wales (NSW) Crime Commission published the Islington Report, an inquiry into money laundering via EGMs in the state. Finding that a “significant amount” of the $95 billion gambled through pokies from 2020 to 2021 was likely the proceeds of crime, the report recommended making all NSW pokies cashless by the end of 2028. 2022 also saw an amendment to the Casino Control Act 1992 allowing NSW casino operators to be fined up to $100 million for compliance failures, a recognition of how serious a problem money laundering had become for the sector. 

Across Australia, many business operating pokies must meet AML/CFT requirements by law, although these differ depending on the number they operate. According to AUSTRAC guidance, businesses licensed to operate up to 15 pokies do not have to have AML/CFT programs in place. However, they must still: 

• Register with AUSTRAC using an AUSTRAC Business Profile Form (ABPF), and keep enrolment details updated. 
• Keep records relating to customer identification procedures and transactions. 
• Submit suspicious matter reports whenever they have reason to believe that a customer’s activity may be linked to money laundering or terrorist financing. 

Businesses operating more than 15 pokies have significantly more obligations. In addition to the above requirements, they must: 

• Appoint a compliance officer. 
• Complete a risk assessment, taking into account their services, customers, and location. 
• Implement an AML/CFT program. 
• Conduct customer due diligence (CDD). 
• Submit reports on transactions above $10,000 in physical cash, including the customer’s identifying information and the transaction date. 
• Regularly review their AML/CFT program and submit annual compliance reports detailing how they meet their compliance obligations. 

Consequences for non-compliance

According to AUSTRAC guidance, non-compliant businesses can face a range of regulatory measures, such as remedial directions or infringement notices. These detail firms’ specific compliance failings and specify the actions they must take to address gaps in their AML/CFT programs, which may include undertaking additional risk assessments or appointing an external auditor. Remedial directions can be made public and, therefore, carry the additional threat of reputational damage for businesses. AUSTRAC can also apply to the Federal Court of Australia for civil fines to be imposed for compliance failures. 

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Compliance challenges for Australian gambling operators

Because of its ubiquity across Australia and its nature as a cash-intensive industry, the gambling sector is under significant pressure to improve its AML/CFT compliance. In doing this, it faces a number of sector-specific challenges: 

• Intensive compliance requirements: AUSTRAC specifies that EGM operators must have customer identification procedures, including determining whether a customer is a politically exposed person (PEP). As part of ongoing due diligence, businesses must also analyze all customer transactions and carry out enhanced due diligence (EDD) if a customer is a foreign PEP or appears to be carrying out suspicious transactions. To do this, firms must have effective solutions in place for customer identification, PEP screening, and transaction monitoring, which all require the use of specialist technology. 
• Potential AML expertise gaps: Despite their high-risk status, gambling operators often lack the dedicated and experienced compliance teams found in financial services firms. In addition to suitable AML software, firms need staff able to carry out practical compliance requirements, such as undertaking risk assessments, handling large cash volumes, making case decisions, filing suspicious matter reports (SMRs), and training other employees on detecting suspicious behavior. Gambling businesses – especially smaller ones not required by law to employ specialist compliance officers – may struggle with the human resources side of compliance. 
• Data quality: Essential compliance program features, such as CDD or transaction monitoring, depend on access to clean, accurate, up-to-date customer- and risk-related information. Firms without this will not be able to fulfill their core AML/KYC requirements in a way that satisfies regulators. 
• Heightened regulatory scrutiny: The gambling sector has come under the spotlight in recent years thanks to high-profile money laundering cases, resulting in new rules for the industry and significant fines for operators guilty of compliance failures. In 2023, the gambling sector suffered the third-highest total regulatory fines, reaching over $475 million. AUSTRAC sanctioned businesses for failures such as inadequate transaction monitoring or EDD measures. 

Best practices for efficient AML compliance

To meet these challenges, there are certain steps EGM operators can take to mitigate their financial crime risks, prepare for potential regulatory scrutiny, and maximize their ability to detect and prevent suspicious behavior. These best practices include: 

• Screening customers against up-to-date information: Gambling operators should empower their screening solutions with the latest data on PEPs, sanctions, and enforcement action. Since this information can change quickly, businesses should make sure they have access to the most recent and accurate data. 
• Implementing smart transaction monitoring: An effective transaction monitoring solution should trigger alerts for customer behavior that is unexpected or inconsistent with their risk profile, as well as more general red flags, such as withdrawing money shortly after gambling it. An automated monitoring solution based on known financial crime typologies and scenarios can help firms with this requirement. 
• Training employees in compliance processes: While technology can do a fair amount of the heavy lifting with certain parts of the compliance process, it must be partnered with a capable team to function effectively. One risk factor flagged by AUSTRAC, for example, involves customers becoming evasive when asked for identifying information or using their rapport with staff to bypass checks. Therefore, all customer-facing employees must be trained to spot red flags and adhere to compliance procedures.

Mitigate your businesses’ risks with advanced AML solutions

ComplyAdvantage’s AML software solutions help gambling operators streamline their compliance without compromising on risk. Firms can benefit from artificial intelligence (AI)-enhanced customer screening, which refreshes PEP and sanctions data in near-real time and allows businesses full visibility into the risks they face. ComplyAdvantage’s screening tools also use advanced matching algorithms to ensure the accuracy of alerts and minimize false positives that could cause unnecessary friction for customers. 

ComplyAdvantage’s transaction monitoring software, meanwhile, is built around a comprehensive rules library of industry typologies, with a no-code rules builder for firms to add their own. Machine learning capabilities fill in any gaps where existing rules cannot detect suspicious activity. With scalability to billions of transactions, our transaction monitoring software helps EGM operators of all sizes protect themselves from the risks of non-compliance. 

The post How to combat money laundering through pokies in Australia appeared first on ComplyAdvantage.

As a predicate offense to money laundering, it’s crucial gambling operators have fraud detection solutions in place to mitigate the risk of “dirty” funds flowing through online gaming platforms and into the legitimate financial system. In this article, gambling operators can learn more about fraudsters’ tactics and discover why implementing proactive fraud prevention strategies is crucial for safeguarding the integrity of online gambling platforms and ensuring a safe and fair gaming environment for all players.

What is online gambling fraud?

Online gambling fraud refers to any illicit or deceptive activity conducted within the realm of online betting and gaming platforms aimed at manipulating outcomes, exploiting loopholes, or defrauding players or the platform itself for financial gain. This type of fraud encompasses various schemes and tactics, including:

• Using stolen credit cards or fraudulent payment methods to fund gambling accounts or withdraw winnings. 
• Rigging the outcome of sporting events or casino games to ensure a specific result, often in collusion with athletes, referees, or employees of the gambling platform. This undermines the integrity of the game and deceives legitimate players.
• Exploiting bonuses and promotional offers provided by online casinos or betting sites through fraudulent means, such as creating multiple accounts or using automated bots to meet wagering requirements unfairly.
• Stealing personal information to create fake accounts or impersonate legitimate users to commit gambling fraud. It can lead to unauthorized access to accounts, fraudulent withdrawals, and other illicit activities.
• Developing or using software tools designed to manipulate the outcome of games, exploit vulnerabilities in the platform’s software, or gain an unfair advantage over other players.

How does online gambling fraud work?

Online gambling fraud centers around exploiting vulnerabilities within online betting platforms. One significant factor contributing to the prevalence of fraud in online gambling is the absence of face-to-face interaction, coupled with the anonymity afforded by digital transactions. 

This environment creates opportunities for fraudsters to exploit loopholes, such as using stolen credit cards or engaging in new account fraud, resulting in financial losses for both operators and legitimate customers.

Fraudsters may collaborate with others to manipulate game outcomes, exploit software vulnerabilities to gain unfair advantages or orchestrate sophisticated scams targeting unsuspecting players. Additionally, techniques like phishing emails and social engineering tactics are employed to illicitly access customer data, further exacerbating the risk of fraud.

The impact of fraud on online gambling

Gaming and gambling websites saw a massive increase in interest during the COVID-19 pandemic when many people were forced to change their habits due to stay-at-home orders across the world. In fact, three times as many people visited online gambling websites in 2020-2021 compared to 2018. However, criminals quickly followed suit to tap into this growing market, leading to the average fraud rate for gambling and betting companies skyrocketing by 80 percent.

While the global online gambling and betting industry generated $536 billion in 2023, and projections indicate it will set new revenue records by reaching $1.4 trillion by 2030, this growth is threatened by the rising rates of online gambling fraud. In addition to undermining consumer trust and confidence in the industry, rising fraud rates could hamper the industry’s continued expansion.

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Common types of online gambling fraud

Some of the primary tactics fraudsters employ in online gambling include:

• The creation of custom code or scripts designed to automatically analyze potential winning odds in various online gambling games such as poker, blackjack, or slot machines. Referred to as value betting, this strategy aims to develop a gambling bot capable of exploiting perceived advantages in the game algorithms.
• When deceitful actions are taken by a third party to benefit from marketing techniques such as pay-per-click (PPC) campaigns. This can involve using stolen data or payment details from an iGaming provider to drive leads for their own business.
• Often websites offer welcome bonuses for new players, which is a way for individuals to take advantage of these promotions and receive more than they’re entitled to. 
• A player depositing funds into their gaming account using a credit card, gambling, and then disputing the charges with their credit card issuer, claiming the transactions were unauthorized or that they did not receive the promised goods or services. This may happen unintentionally if, for example, a child uses their parent’s mobile device to make a gambling-related payment unbeknownst to the parent, who subsequently reports it as fraud.

Advanced fraud detection solutions powered by AI

The predictive capabilities of advanced fraud detection software can help gambling operators anticipate and thwart potential fraud schemes. Some solutions have even been shown to offer significant reductions in all payment fraud-related losses. By harnessing predictive analytics, firms can effectively safeguard against fraudsters’ constantly evolving gambling fraud tactics, ensuring enhanced security and peace of mind.

Robust customer screening solutions are just as vital, helping operators know who they’re doing business with and whether certain entities should receive more due diligence surrounding their gambling activity. Solutions that can also screen customers against sanctions and watchlists, politically exposed persons (PEPs), adverse media, and enforcement data are particularly valuable, especially those that use artificial intelligence (AI) matching algorithms to ensure alert accuracy and reduce the likelihood of duplicated profiles. 

The post What is online gambling fraud, and how can it be prevented? appeared first on ComplyAdvantage.

While traditional casinos can provide criminals with an avenue to convert physical “dirty” cash into casino chips, online gambling presents various different types of money laundering risks due to one aspect in particular: increased levels of anonymity. 

This article details the financial red flags compliance staff should be aware of and provides best practices for mitigating these risks.

Money laundering risks in online gambling

To mitigate financial crime risks effectively, firms must be able to recognize red flag behaviors and activities in online gambling transactions. Understanding these indicators enables firms to fine-tune and customize their systems to align with their risk appetite and address the challenges online gambling poses within their industry and jurisdiction. 

Some key money laundering risks in online gambling include:

• Unlike traditional casinos that require face-to-face interactions, online platforms allow users to gamble with minimal personal information. Criminals often exploit this by using stolen credit cards, fake identities, or cryptocurrencies to place bets and withdraw their “winnings,” effectively laundering their illegally obtained money.
• It’s common for online gambling sites to permit the creation of multiple accounts, which criminals can use to transfer money between accounts to obfuscate the origin of the funds. 
• Like traditional casinos, online gambling platforms facilitate the movement of large sums of money, making it easier for criminals to integrate their dirty money into the legitimate financial system. 
• Each jurisdiction regulates online gambling differently, which can create challenges for authorities attempting to combat financial crime, including money laundering. Some countries have strict regulations and robust monitoring systems (e.g., China), while others have more relaxed approaches (e.g., Malta). This inconsistency can create loopholes that criminals exploit to launder money through online gambling platforms.

Money laundering schemes in online gambling 

Online gambling platforms can be exploited by bad actors at each of the three stages of money laundering:

1. Placement: Illicit funds are introduced into the financial system by depositing money into gambling accounts.
2. Layering: The source of the funds (SoF) is disguised through complex transactions involving multiple bets, transfers, and withdrawals within the gambling platform.
3. Integration: The laundered funds are withdrawn or used for legitimate transactions.

Understanding each of these stages can help compliance teams identify some of the common schemes fraudsters use to launder money through online gambling platforms. Key methods include:

• Smurfing: Breaking down large sums into smaller, less noticeable transactions to evade detection.
• Coordinated betting: Placing bets with deposited funds, colluding with other players, and making coordinated bets to obscure the money’s origin.
• Chip dumping: Intentionally losing chips to another player at an online poker table to transfer funds covertly.
• Player-to-player transfers: Using gambling accounts to facilitate illegal transactions between parties through direct transfers.
• Gnoming: Utilizing multiple accounts to help one player win and another lose in head-to-head games.
• Concealment: Hiding illicit funds in gambling accounts without immediate withdrawal, using the same anonymous banking method for future retrieval.

AML regulations for online gambling

In the US, online gambling falls under federal and state jurisdiction, with laws like the Wire Act governing interstate betting and payment processing. However, the Financial Crimes Enforcement Network (FinCEN) does expect online casinos to have the same robust Bank Secrecy Act (BSA) and AML programs as traditional brick-and-mortar casinos. In fact, in June 2021, FinCEN issued its first government-wide priorities for AML and countering the financing of terrorism (CFT) policy pursuant to Section 5318(h)(4)(A) of the BSA. The regulator’s new policy identified eight national priorities for all bank and non-bank FIs covered by the BSA, including online gambling establishments, that must be incorporated into existing BSA/AML programs. The eight priorities include:

1. Corruption
2. Cybercrime
3. Foreign and domestic terrorist financing
4. Fraud
5. Transnational criminal organization activity
6. Drug trafficking organization activity
7. Human trafficking and human smuggling
8. Proliferation financing

Meanwhile, the EU lacks unified gambling legislation, with member states like France, Italy, and Spain each governing their regulations at the national level. These entities enforce licensing, consumer protection, and anti-fraud measures.

In the UK, the Gambling Commission oversees online gambling regulation, ensuring compliance with laws like the Gambling Act 2005. Specifically, all operators must comply with the following:

• The Proceeds of Crime Act 2002 (POCA).
• The Terrorism Act 2000. 
• The Gambling Act 2005. 

Penalties for non-compliance

The UK’s Gambling Commission has the authority to issue fines for breaches of the Gambling Act 2005. These fines can range from a percentage of annual revenue to substantial fixed penalties, depending on the severity of the violation – non-compliant operators may face license suspension or cancellation.

Similarly, in the EU, member states enforce penalties for non-compliance with gambling regulations. For example, under France’s Autorité de Régulation des Jeux En Ligne (ARJEL), operators can face fines of up to €30,000 for violating licensing conditions or regulatory requirements. Repeated offenses may lead to higher fines or even license suspension or cancellation.

In the USA, penalties for failing to comply with online gambling regulations vary at both the federal and state levels. Under the Unlawful Internet Gambling Enforcement Act (UIGEA), FIs can face civil penalties for processing illegal gambling transactions, with fines reaching up to $1 million per violation. Operators may also face prosecution under state-specific laws, such as New Jersey’s Casino Control Act, which imposes fines of up to $200,000 for each regulatory violation. Regarding BSA violations, the US government imposes statutory penalties – which can range from $10,000 dollars for record-keeping violations to over $200,000 for more serious infractions. 

Money laundering red flags in online gambling

Recognizing financial red flag indicators about online gambling money laundering is crucial to helping firms develop and implement specific rule sets to identify and mitigate risks, ensuring they do not inadvertently facilitate illegal activities. Some common indicators of potential money laundering in online gambling include:

• Players who consistently place large bets on low-risk games or matches.
• Individuals making numerous substantial deposits or withdrawals within a short time.
• Gaming deposits originating from cryptocurrency. In February 2024, the UK Gambling Commission reminded operators that crypto-assets are considered high-risk, and licensees must appropriately scrutinize crypto transactions throughout customer and business relationships.
• Operating multiple accounts under different names or using various IP addresses.

How can online gaming platforms mitigate money laundering risks?

Firms can enhance their defenses against online gambling risks with the right application of due diligence, software, and training. Some best practices include:

• Ensuring risk assessments align with the latest red flag indicators. This should include evaluating the risks associated with specific products and services, taking into account the user and the product’s functionality.
• Implementing blockchain technology, giving online gambling companies a transparent way to record transactions.
• Providing comprehensive staff training on AML procedures and regulations to ensure compliance and fostering a culture of vigilance within any organization. Regulations in 21 US jurisdictions mandate that online gaming operators must prepare and submit a plan for addressing responsible gaming issues, which must include employee training and public awareness efforts.

Detect money laundering with advanced AML solutions

Advanced AML solutions employ a mix of sophisticated techniques to help compliance teams effectively monitor and prevent illicit financial activities. At the core of these strategies is transaction monitoring, which scrutinizes financial transactions to spot suspicious activities. Utilizing cutting-edge machine learning algorithms, these systems can identify irregular patterns like significant transfers to offshore accounts, recurring high-value transactions, or movements inconsistent with a customer’s usual profile, triggering alerts for further investigation.

Customer screening is also vital as it aims to verify the identities of both new and existing customers against databases of known criminals, politically exposed persons (PEPs), and sanctioned individuals. This step is crucial for preventing high-risk individuals from using online gaming platforms for money laundering, helping firms mitigate the risk of non-compliance and protect their reputations in the market. 

The post Money laundering through online gambling appeared first on ComplyAdvantage.

While the market size of the casino and online gambling industry was forecast to reach $261.8 billion in 2022 – representing a $54.5 billion increase from 2021 – more and more casinos are being held responsible for their insufficient anti-money laundering (AML) controls. In 2022 alone, reports show casino regulators in the US, the UK, Austria, Sweden, and the Netherlands issued over $264 million in fines to casinos – representing a 444 percent increase over 2021.

How does casino money laundering work?

In many cases, criminals exploit the anonymity provided by the casino environment. Gamblers can give the casino incorrect, incomplete, and/or vague identifying information, meaning red flags may not be raised around their identity. When playing in an online casino, they can also create and use multiple accounts, which means suspicious transactions are not noticed quickly.

A common technique in casino money laundering involves converting “dirty” money into physical casino chips, which are then played with in various games before being cashed out as “clean” money in the form of a check. Fixed-odds betting terminals are often used in this laundering method, as they allow the gambler to only lose a small amount before cashing out. 

Legal and illegal casinos

Casino money laundering can take place in both legal and illegal gambling establishments:

• Legal casinos – these casinos need to be licensed and are required to pay taxes. 
• Illegal casinos – these undercover casinos are not licensed and do not pay taxes.

According to the US Department of Justice (DOJ), illegal casinos are one of the five major types of illegal gambling – the other types being sports betting with bookmakers, horse betting with bookmakers, sports parlay cards, and numbers (also known as “the Mafia lottery” or “the numbers racket”). 

In a joint operation carried out in September 2021, INTERPOL commented on the common convergence of illegal gambling with organized crime networks and money laundering efforts. The city of Los Angeles, California, has experienced this on an unprecedented scale since the COVID-19 pandemic, with illegal casinos (known as “casitas”) emerging “everywhere” under the control of the Mexican Mafia. According to authorities, the illegal casinos can generate tens of thousands of dollars per week, with the proceeds primarily benefiting incarcerated members of the gang. In addition to contributing to elevated levels of crime – such as drug use, shootings, and kidnappings – illegal casinos present a higher risk of money laundering as gamblers and organized crime members look for ways to make their winnings appear legitimate in the financial system. 

Casino money laundering examples

Incidents of money laundering through casinos have repeatedly made headlines over the past few years, with some jurisdictions facing a great deal of scrutiny for insufficient anti-money laundering (AML) measures and slow enforcement proceedings. 

Macao, China

While gambling is strictly prohibited in China, it is permitted in the special administrative region of Macao. However, Thomson Reuters found that Macao “has not scrutinized money laundering risks in the gaming industry with as much rigor as casino regulators in other jurisdictions.” Following this report, an amendment to gambling laws now means that Macao’s Chief Executive can revoke a casino’s license if it fails to pay its taxes on time, or on national security grounds. 

Australia

Additional examples of money laundering in casinos can be found throughout Australia. In March 2022, the Australian Transaction Reports and Analysis Centre (AUSTRAC) started federal proceedings against’s the country’s largest casino operator, Crown Resorts. Crown’s alleged failings include not undertaking appropriate ongoing customer due diligence (CDD) on high-risk customers and not having a risk-based transaction monitoring program to identify suspicious activity. As of March 2023, Crown’s proceedings are still underway.

Following the investigation into Crown Resorts, AUSTRAC fined casino operator Star Entertainment a record $100 million in November 2022, after discovering the company allowed gamblers to move money through non-transparent channels. Among the failings that led to the operator’s penalty included making misleading representations about its processes and systems for compliance with AML and counter-terrorism financing (CTF) obligations. 

In the following month, AUSTRAC also commenced civil penalty proceedings against major Australian casino operator SkyCity Adelaide for alleged “serious and systemic non-compliance”. Similar to Star Entertainment, it is alleged that SkyCity failed to include appropriate risk-based systems and controls in its AML/CTF program.

To combat the rising threat of money laundering in the gambling sector, AUSTRAC launched a second specialist AML unit in March 2023. 

Canada

Additionally, in June 2022, a report by the Cullen Commission found “staggering” amounts of “lavish” money laundering schemes and serious compliance failings throughout Canada’s province of British Columbia, particularly in the gambling/gaming industry. The report found that drug traffickers and organized crime gangs often used casinos to “snow wash” money gained via illegal activities. 

As a result, the commission encouraged British Columbia to instate an AML commissioner, begin a dedicated money laundering investigation, and implement an intelligence police unit to address the “corrosive form of criminality”.

Measures to prevent money laundering in casinos

Global regulators and the Financial Action Task Force (FATF) are keen to enforce AML and counter-terrorist financing (CTF) regulations around the gambling industry. The FATF flagged the vulnerability of casinos for money laundering and terrorist financing when it revised its 40 recommendations.

Casinos can proactively mitigate the risk of money laundering by implementing the following measures:

• Train staff on AML: Employees should be coached and well-trained so they can confidently recognize red flag indicators of money laundering and fully understand the process of reporting suspicious activity to the relevant authorities.  
• Participate in industry forums: Forums, like those run by the UK Gambling Commission, often share best practices and support AML/CTF policy development.
• Comply with AML regulations: In some countries, gambling is completely illegal. In others, such as Japan, it is heavily controlled and regulated. Many jurisdictions have strict AML rules that apply to casinos as well. In the US, for example, casinos must comply with the Bank Secrecy Act. AML regulations will often require casinos to undertake customer due diligence (CDD), maintain comprehensive records, and commit to reporting obligations.
• Employ a risk-based approach: Not all risk is created equal. Casinos should adopt a risk-based approach to AML to assign the appropriate level of resources to high-risk areas — such as “VIP customers” —  who are more likely to spend larger amounts of money.

Risk indicators for money laundering in casinos

What are some of the red flags for money laundering in casinos?

Of the suspicious activity reports (SARs) that US enforcement body the Financial Crimes Enforcement Network (FinCEN) received from casinos, common issues reported included: :

• Suspicious behavior and/or more than one gambler seeming to be working together
• Large amounts of cash or chips spread over only a few bets
• Betting amounts just below the reporting threshold
• Customers abandoning their jackpot winnings
• Customers having a large quantity of chips
• Customers making changes to bets to avoid reaching the threshold

Other things that casino AML and KYC teams may notice include:

• A discrepancy between the amount cashed in and the amount cashed out – in one case examined by the FATF an individual was named as winning $1m but not recorded as bringing any cash in
• Customers closing their casino account after the initial deposit
• Clients transacting across different locations
• Clients having access to multiple bank accounts registered abroad
• Clients asking questions about thresholds or having in-depth knowledge of thresholds
• Rapid or large transactions
• Customers trying to make friends with casino employees 

Casinos also need to keep a close eye on individuals from sanctioned countries and avoid breaking sanctions laws.

AML solutions for casinos

Casino AML compliance teams are seeing a perfect storm as the cost-of-living crisis fuels financial crime while firms’ profits – and therefore capital available to invest – is under pressure. To balance these pressures and mitigate the risk of money laundering, casinos should ensure their customer screening software is set up in accordance with geographic regulatory differences and is able to update in real-time. 

Each facility’s transaction monitoring solution must also be able to handle large transactions, especially those that are cash-based. Therefore, a solution with easily adjustable thresholds and a high level of configurability should be prioritized. Casinos must also be prepared to report any suspicious activity to the relevant authorities. 

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