• Casinos

    Many services provided by casinos are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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What are the ML/TF Risks?

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.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for the casino industry.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

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