• Online Gambling

    Online gambling is attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Online Gambling

What are the ML/TF Risks?

The online gambling industry is attractive to criminals wanting to launder the proceeds of crime.

Online gambling may also have become more attractive to criminals over the past few years as the financial sector has implemented comprehensive AML/CFT measures.

Online gambling is vulnerable to money laundering activities for various reasons, such as ease of access, cross border activity, alternative payment systems and high turnover.

The Money Laundering and Terrorist Financing (ML/TF) risks associated with online gambling include:

  • The avoidance of direct involvement in the money laundering process, through the use of people unrelated to the initial criminal activity.  These are known as ‘front people’ through whom gaming transactions are channelled;
  • Online gaming companies can credit winnings or unused funds back to an account other than the one through which the original bet was made;
  • Peer-to-peer transfer of funds between accounts;
  • Significant volumes of transactions, and the need for quick processing of payments;
  • Online gaming may be used as a vehicle for the laundering of money through peer-to-peer games such as e-poker;
  • Fund account with large deposits, wager a minimal amount, then withdraw funds; and
  •  VIP rooms and high-stake gambling facilities.

Online gambling 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 online gambling 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.

Who has used AML Accelerate in this sector?


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