Gaming machine venues (hotels, pubs and clubs) are attractive to criminals wanting to launder the proceeds of crime.
Gaming machine venues may also have become more attractive to criminals over the past few years as the financial sector has implemented comprehensive AML/CFT measures.
The Money Laundering and Terrorist Financing (ML/TF) risks associated with gaming machine venues include:
- The avoidance of direct involvement in the money laundering process, through the use of “front people, mules and clean skins” through whom gaming transactions are channelled;
- Exchanging illicit cash for gaming tokens. The 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;
- VIP rooms and high-stakes gambling; and
- Electronic gaming machines – used to launder smaller amounts of cash.
Gaming machine venues such as hotels, pubs and clubs 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.