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The prevention of money laundering and combating the financing of terrorism

Transaction risk (including means of payment)

2.22 Casinos should consider operational aspects (products, services, games, accounts and account activities) that can be used to facilitate money laundering and terrorist financing. In addition, land-based and remote casinos have the following potential transaction risks:

  • proceeds of crime – there is a risk that the money used by a customer has been gained through criminal activity, so greater monitoring of high spenders will help to mitigate the risk
  • cash – customers may use non-remote casinos to exchange large amounts of criminal proceeds, or may deposit criminal proceeds into an internet gambling account at a non-remote casino
  • transfers between customers – customers may transfer money between themselves or may borrow money from unconventional sources, including other customers, which can offer criminals an opportunity to introduce criminal proceeds into the legitimate financial system through the casino
  • use of casino deposit accounts – criminals may use accounts to deposit criminal proceeds and then withdraw funds with little or no play
  • redemption of chips, tickets or tokens for cash or cheque, particularly after minimal or no play
  • particularly in remote casinos:
    • multiple gambling accounts or wallets – customers may open multiple accounts or wallets with an operator in order to obscure their spending levels or to avoid CDD threshold checks
    • changes to bank accounts – customers may hold a number of bank accounts and regularly change the bank account they use for the remote casino operator
    • identity fraud – details of bank accounts may be stolen and used on remote gambling websites, or stolen identities may be used to open bank accounts or remote gambling accounts
    • pre-paid cards – these cards pose the same risks as cash, as remote casino operators normally cannot perform the same level of checks on the cards as they can on bank accounts
    • e-wallets – some e-wallets accept cash on deposit or cryptocurrencies, which pose a higher risk, and some customers may use e-wallets to disguise their gambling
    • games involving multiple operators – for example, poker games often take place on platforms shared by a number of remote gambling operators, which can facilitate money laundering by customers, such as chip dumping.

Next chapter: Product risk