Guidance
The prevention of money laundering and combating the financing of terrorism
Gambling Commission guidance for remote and non-remote casinos: Fifth edition (Revision 3).
4 - What constitutes suspicious activity?
There are numerous things that can make someone either know or suspect that they are dealing with the proceeds of crime. Some examples of how suspicions may be raised are listed as follows, although this is not an exhaustive list and there may be other circumstances which raise suspicion.
Examples
- A man convicted of dealing in drugs is released from prison and immediately starts gambling large amounts of money. He is known to be out of work and other customers inform employees that he is supplying drugs again. This will give rise to the suspicion that he is spending the proceeds of his criminal activity.
- Stakes wagered by a customer become unusually high or out of the ordinary and the customer is believed to be spending beyond their known means. This requires some knowledge of the customer but, nevertheless, there may be circumstances that appear unusual and raise the suspicion that they are using money obtained unlawfully. It may be that the customer lives in low cost accommodation with no known source of income but nonetheless is spending money well above their apparent means. There is no set amount which dictates when a SAR should be made and much will depend on what is known or suspected about the customer.
- A customer exhibits unusual gambling patterns with an almost guaranteed return or very little financial risk (sometimes across multiple operators). It is accepted that some customers prefer to gamble in this way but, in some instances, the actions may raise suspicion because they are different from the customer’s normal gambling practices.
- Money is deposited by a customer or held over a period and withdrawn by the customer without being used for gambling. For instance, suspicions should be raised by any large amounts deposited in gaming machines or gambling accounts that are then cashed out or withdrawn after very little game play or gambling.
- A customer regularly gambles large amounts of money and appears to find a level of losses acceptable. In this instance, the customer may be spending the proceeds of crime and sees the losses as an acceptable consequence of the process of laundering those proceeds.
- A customer’s spend increases over a period of time, thereby masking high spend and potential money laundering.
- A customer spends little, but often, and their annual aggregate spend is high and out of kilter with their expected spend. This could indicate potential money laundering.
- A customer displays gambling patterns where spend is high, but the risk is low, for example gambling on red and black in roulette. The customer could be laundering money in a way that guarantees minimal loss.
- A customer gambles with significant amounts of money in a currency without a reasonable explanation for the source of that currency, such as Scottish and Northern Irish bank notes presented by a customer in an English casino.
- Instances of high spend by customers that lead to significant commercial risk for the operator may also indicate suspicious activity.
It is important to note that, once knowledge or suspicion of criminal spend is linked to a customer in one area of the business (for example, table games), it is good practice to monitor the customer’s activity in other areas of the business (for example, gaming machine play).
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Internal reporting
Last updated: 30 May 2023
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Updated in line with version 3 of the guidance. References to 'proliferation financing' added.