Casinos are attractive to criminals wanting to launder the proceeds of crime.
Casino may also have become more attractive to criminals over the past few years as the financial sector has implemented comprehensive AML/CFT measures.
Casino are vulnerable to money laundering activities as many casinos offer services similar to financial institutions, including accounts, foreign exchange, money changing, and electronic funds transfers.
The Money Laundering and Terrorist Financing (ML/TF) risks associated with casinos include:
- The avoidance of direct involvement in the money laundering process, through the use of “front people, mules and cleanskins” through whom gaming transactions are channelled;
- Exchanging illicit cash for casino chips or gaming tokens. The chips or tokens are then cashed-in as ‘winnings’ linking the money to a legitimate source;
- Significant volumes of transactions, and the need for quick processing of payments;
- Casino VIP rooms and high-stakes gambling;
- Electronic gaming machines – used to launder smaller amounts of cash; and
- Junkets that target wealthy gamblers and offer them free accomodation, travel and other perks with the expectation of a minimum daily wager and a minimum amount of time spent at the tables gambling.
Casinos must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.