• Hotels, Pubs and Clubs (Gaming Machine Venues)

    Many services provided by gaming machine venues such as hotels, pubs and clubs are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Hotels, Pubs and Clubs (Gaming Machine Venues)

What are the ML/TF Risks?

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.

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 gaming machine venues such as hotels, pubs and clubs.

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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