Specialised Solutions for Online Casinos’ AML/CFT Compliance Management

We offer a comprehensive set of anti-money laundering (AML), counter-terrorist financing (CFT), and fraud prevention solutions for online casinos' anti-money laundering compliance that are tailored to applicable AML/CTF (aka CTF) laws, regulations, AML/CTF supervisors' guidance for the online gambling sector, sector-specific red flags and indicators, to help your business meet applicable obligations that cover online gambling money laundering and terrorist financing risk mitigation, fraud prevention, the detection and handling of other types of financial crime.

We have designed our AML solutions to help you navigate the complexities of online casinos' AML requirements in a commercially oriented and goal-focused manner, providing effective AML/CTF support for all aspects of online casinos' AML compliance, including but not limited to:

• Business Profile and Strategic Factors:
• Your commercial objectives
• Your products
• The size and structure of your business
• Your available AML/CTF compliance technology and resourcing
• Your risk appetite for AML/CTF-related risks
• Your governance framework and reporting lines
• Your client demographics
•  Your countries of operation

 

• Applicable Regulatory and Fraud Prevention Obligations:
• AML/CTF regulations for online casinos
• Any online casinos' fraud prevention obligations or expectations your business may be subject to
• Any related compliance obligations, including, but not limited to, online casinos’ obligations under:

• Privacy laws
• Financial market laws
• Fair trading laws
• Financial licensing requirements
• Other relevant regulatory frameworks

• Operational AML/CTF Compliance Requirements:

• Money laundering and terrorist financing (ML/TF) risk assessment
• AML risk management
• Customer due diligence (CDD) and Know Your Customer (KYC) obligations for online casinos
• Enhanced customer due diligence
• Ongoing customer due diligence and transaction monitoring
• PEP identification and sanctions compliance
• Staff vetting and AML/CTF training
• Ad-hoc and periodic reporting
• Other obligations relating to online casinos' anti-money laundering, counter-terrorist financing and sanctions compliance, as well as financial crimes prevention

 

 

What Jurisdictions Do Our Online Casinos’ AML Solutions Cover?

• Online Casinos' AML Solutions in Singapore: Online casinos' AML obligations in Singapore are governed by the Casino Control Act and the Gambling Control Act 2022, ensuring robust monitoring of gambling activities to prevent money laundering. Supervision is managed by the Gambling Regulatory Authority of Singapore (GRA).
• Online Casinos' AML Solutions in Malta: Online casinos' compliance requirements in Malta are outlined in the Gaming Act of 2018 and its subsidiary legislation, administered by the Malta Gaming Authority (MGA). Online casinos are also subject to the European Union's AML directives, including AMLD6, as Malta is an EU member state.
• Online Casinos' AML Solutions in Gibraltar: Online casinos' AML requirements in Gibraltar are established under the Gambling Act of 2005, managed by the Gibraltar Gambling Commissioner.
• Online Casinos' AML Solutions in Curacao: Online casinos' AML obligations in Curacao are governed by the National Ordinance on the Reporting of Unusual Transactions (NORUT) and the National Ordinance on Identification when Rendering Services (NOIS), with the Curaçao Gaming Control Board (GCB) as a supervisor.
• Online Casinos' AML Solutions in the United Kingdom: Online casinos' AML obligations in the United Kingdom are detailed in the Money Laundering Regulations 2017 and its subsequent updates with guidance from the UK Gambling Commission.
• Online Casinos' AML Solutions in the USA: Online casinos' AML requirements in the USA are governed by the Bank Secrecy Act and various state-specific regulations, with supervision primarily by the Financial Crimes Enforcement Network (FinCEN) for AML compliance, alongside state-level gaming commissions where applicable.
• Online Casinos' AML Solutions in the European Union: Online casinos' compliance requirements in the European Union adhere to the Sixth Anti-Money Laundering Directive (AMLD6), with oversight coordinated by the European Banking Authority (EBA) and enforced by national regulators in member states.
• Online Casinos' AML Solutions in Australia: Online casinos' AML obligations in Australia are set out in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, ensuring that online gambling sites effectively monitor gambling accounts to prevent money laundering through online gambling. Supervision is managed by the Australian Transaction Reports and Analysis Centre (AUSTRAC).
• Online Casinos' AML Solutions in New Zealand: Online casinos' AML requirements in New Zealand are defined the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, ensuring online gambling platforms comply with regulations to prevent online gambling money laundering. Oversight is provided by the Department of Internal Affairs (DIA).

 

 

Which Types of Online Gambling Providers Do We Support?

Focusing on money laundering (ML), terrorism financing mitigation (TF), and online casinos' fraud prevention, our online casinos' AML solutions cover the following types of online gambling service providers and institutions that are deemed to be AML/CTF designated service providers (aka "reporting entities" ):

• Online Betting Platforms
• Sportsbook Operators
• eSports Betting Sites
• Poker Rooms
• Casino Game Providers
• Lottery and Bingo Services
• Virtual Currency Gambling Sites
• Mobile Gambling Applications
• Other gambling providers that are subject to the online casinos' AML obligations

Online Casinos’ AML Advisory and Support

Our AML/CFT advisory services for online casinos include, but are not limited to, the following:

• Detailed AML/CTF compliance advice: Tailored to the online casinos' AML requirements for different processes, including but not limited to customer due diligence (CDD), transaction risk scoring, transaction monitoring, customer onboarding and know-your-customer (KYC) analysis, and other AML processes. Also tailored to the specific money laundering and terrorist financing (ML/TF) risks involved in these processes, helping you with effective ML/TF risk management.
• Online casinos' fraud risk management advice: Advising on measures, controls, and processes for detecting, preventing, and responding to different types of fraud, scams, and other types of financial crime relevant to online casinos. Also, tailored to online casinos' fraud environment, risk management practices, and stakeholders' expectations and obligations (banks, regulators, insurers, shareholders, etc.).
• Banking relationships advice: Advising online gambling businesses on AML/CTF issues related to maintaining and expanding their banking relationships, complying with banks' AML/CTF risk appetite standards, recall procedures and expectations, and other operational requirements.
• Operational AML/CTF advice: Advising support and KYC teams on day-to-day onboarding, support queue management processes, allocating AML/CFT resources effectively, and making operational improvements to enhance overall customer experience and AML compliance efficiency.
• Specific matter advice (difficult clients, high ML/TF risk matters, customer due diligence for high-net-worth clients, complex transactions and more): Advising on handling specific AML/CTF issues related to clients and complex and unusual transactions, including assessing the adequacy of Sources of Wealth (SOW) or Source of Funds (SOF) information and documentation for specific enhanced due diligence (EDD) cases.
• Peer benchmarking and best practices: Helping online casinos compare their AML/CFT practices with industry standards, AML/CTF supervisor guidance, and internationally recognised best practices set up by international organisations like the Financial Action Task Force (FATF) for complying with online casinos' AML/CFT obligations.
• Government agencies liaison advice: Advising senior management and compliance teams on handling relationships with external bodies, including AML/CTF supervisors and law enforcement agencies, such as the FIU or its local equivalents.
• AML/CFT audit advice: Advising senior management and compliance teams on matters related to the statutory AML/CFT audits, including auditors' guidelines, requirements, AML/CFT audit process, and obligations related to the audit's outcome, tailored to both generic online casinos' anti-money laundering compliance obligations and your specific situation.
• AML/CFT remediation advice: We help online casinos to effectively navigate situations involving an AML/CFT breach, warning, or investigation. The cost of non-compliance can result in significant regulatory fines and penalties, as well as irreparable reputational damage. Therefore, when you are on your supervisor's radar, it's essential to have AML/CFT advisors who know how to set things right and effectively engage with AML/CFT supervisors and other stakeholders. For more details, please visit our Remediation Solutions page.
• Further information: You can visit our AML advisory page for an extensive list of AML/CFT advisory services we offer to support online casinos' anti-money laundering compliance, as well as AML/CFT compliance for other types of financial institutions and businesses subject to the AML/CFT regime.

 

AML/CFT Training and Capacity Building

We offer the following set of AML/CFT training and education solutions tailored to online casinos' AML/CFT compliance requirements:

• Customised AML/CFT Training Solutions: Specialised AML training sessions for various teams, including management, compliance, operations, sales, and customer relations, focusing on the online casinos' AML requirements, AML/CFT awareness, best practices, and ML/TF red flags.
• Up-to-date Regulatory AML Updates: Keeping your compliance officers, managers, and teams updated with changes in the online casinos' AML requirements, AML regulations and guidance.
• Workshops on Emerging Trends and Red Flags: Advising on new AML trends, red flags, and typologies relevant to online gambling money laundering, terrorist financing, fraud, and other types of financial crime.
• Practical Workshops: Interactive workshops for effective and goal-oriented AML/CTF compliance, capacity planning, and resource allocation, covering:

• KYC procedures for online casinos
• KYB analysis and ML/TF risk assessment application to specific clients, transactions and situations
• The online gambling money laundering risks, common money laundering schemes and terrorist financing methods
• Improvements in clients' onboarding and transaction monitoring procedures
• Reg-tech for AML compliance
• Internal and external AML/CTF reporting
• Related risk and compliance issues, including financial crime prevention
• Application of the risk-based approach to online gambling money laundering, fraud risks, and terrorism financing
• Suspicious matter reporting guidelines
• The implementation of customer identification programs and KYC procedures
• Strategic and operational ML/TF risk management
• AML/CTF specifics of the cross-border online gambling services
• Other obligations related to the online casinos' AML requirements

• Practical Compliance Applications: Ensuring the practical application of training, focusing on real-world online gambling money laundering, terrorist financing, and common online casinos' fraud scenarios, as well as specific challenges related to the online casinos' AML/CTF compliance that your business is likely to face.
• Further information: You can visit our AML training solutions pagefor an extensive list of AML/CFT training solutions we offer to online casinos and other businesses subject to AML/CFT regulations.

 

Comprehensive AML/CFT Managed Solution for Online Casinos

Our online casinos' AML/CFT compliance management solutions include but are not limited to:

• AML/CFT Compliance Leadership: We act as your dedicated AML/CFT compliance officers (aka "Money Laundering Reporting Officers" or (MLROs)) and as compliance managers, fully managing AML/CFT compliance and handling the online casinos' anti-money laundering obligations for your business.
• Online Casinos' Anti-Money Laundering Risk Management: Conducting detailed assessments to identify ML/TF risks, assess their inherent impact and likelihood of occurrence for your business, evaluate the effectiveness of mitigations and controls in place, and formulate residual risk ratings.
• Managing Client Onboarding Process and Customer Due Diligence: Implementing robust Know Your Customer (KYC), Know Your Business (KYB), customer due diligence (CDD), and enhanced due diligence (EDD) processes, for all types of clients, including higher ML/TF risk clients.
• PEP and Sanctions Screening: Managing thorough compliance with AML surveillance requirements by screening against global sanctions and politically exposed persons (PEPs) lists. This covers both initial and ongoing screening, as well as escalation processes for true positives.
• UBO Verification Streamlining: Verification of beneficial ownership in line with the online casinos' AML requirements, identifying and assessing individuals who hold ultimate control over assets. This includes initial and ongoing checks, with procedures to address discrepancies and high-risk cases as they arise.
• AML Transaction Monitoring: Developing and implementing a set of business-specific ML/TF alerts and red flags to detect and report suspicious transactions, helping you comply with the online casinos' AML requirements in a commercially efficient manner without making AML/CFT compliance a business hindering factor.
• Transaction Monitoring and Online Casinos' Fraud Prevention Solution: Related to the above, we also help with the implementation of fraud alerts and red flags to detect, prevent, and respond to fraudulent transactions and activities.
• AML/CFT Tech Handling: Leading the alignment of AML/CFT technology implementation with your business processes and AML/CFT objectives. This also includes reviewing AML/CFT technology against the online casinos' AML requirements and your core policies and procedures.
• AML/CTF and Data Sharing: Handling information requests from law enforcement agencies, AML/CTF supervisors, and other relevant AML/CTF-designated entities—such as your banking partners, FX platforms, liquidity providers, finance providers, etc.—to help you manage your AML/CTF compliance-related communications.
• Internal AML/CFT Reporting Solutions: Facilitating structured reporting workflows for your board and its delegate committees, with a specific focus on AML/CFT compliance. This includes:

• preparing and presenting comprehensive AML/CFT performance metrics
• providing insights into AML/CFT compliance effectiveness
• reporting on the effectiveness of internal controls and mitigations for your general AML/CFT obligations and the sector-specific online gambling money laundering risks
• identifying areas for improvement

Our AML/CFT compliance reports cover:

• your ongoing compliance status in relation to online casinos' AML requirements
• ongoing progress against your organisation-wide AML/CFT compliance calendar
• alignment of your business's AML/CFT performance with specific project goals and relevant KPIs
• other factors to ensure that the management function is well-informed and aligned with the AML/CFT compliance requirements for online gambling providers.

• Online Casinos' AML and Externally Reportable Matters: Implementing effective external reporting procedures to help you comply with online casinos' anti-money laundering requirements for reporting captured activities and transactions. This includes managing externally reportable matters covered by the following report types: Suspicious Activity Reports (SARs), Suspicious Matter Reports (SMRs), Suspicious Transaction Reports (STRs), Prescribed Transaction Reports (PTRs), Threshold Transaction Reports (TTRs), and their equivalents.
• Periodic AML/CFT Reporting: Organising and overseeing the preparation, data storage, and effective submission of required periodic reports to your AML/CTF supervisors, helping you comply with online casinos' AML requirements for statutory reporting.
• Online casinos' Fraud Prevention Management: Implementing targeted fraud prevention measures, enhancing internal controls, and helping you comply with internal policies and external regulations. We work to mitigate fraud risks without disrupting business processes, aligning fraud prevention efforts with your broader compliance objectives.

 

KYB Solutions for Online Casinos’ Anti-Money Laundering Compliance

We offer a range of KYB solutions to help you effectively comply with online casinos' AML requirements. These include:

• Establishing ML/TF risk scoring models and parameters for different risk categories: We establish criteria to assess the ML/TF risk levels of your client base by identifying key risk factors based on their business nature, activities, jurisdictions, and other relevant characteristics and develop a risk scoring model to classify clients into different ML/TF risk categories such as low, medium, and high risk.
• Implementing a Customised KYB Process: We can help you roll out the KYB process across all departments to help your teams become sufficiently trained and equipped to handle clients' ML/TF risk effectively when it comes to verification, monitoring, ongoing due diligence, and other processes.
• KYB Technology and Automation: We select and evaluate technologies that can automate various parts of the KYB process, such as data collection, risk scoring, sanctions screening solutions, and ongoing monitoring.
• KYB-Related Escalation Process: We can develop and implement a clear escalation procedure for handling high-risk clients or irregularities, including the triggers for escalation, the actions required at each step, and the responsibilities for resolving these issues.

 

 

Core Policies and Procedures for Online Casinos’ AML/CFT Compliance

We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective online casinos' AML/CFT compliance management, including the following:

• Online casinos' AML/CFT Framework Development: Covering specific online casinos' AML requirements and obligations under national AML/CTF laws and regulations, any applicable AML/CFT guidance, your risk appetite, your existing human and technology resources, your business structure, your history of AML/CFT compliance, and your current and future business goals.
• AML/CTF Risk Assessments: Focused on the online casinos' AML requirements for risk management as they relate to specific ML/TF risks faced by your business in terms of its size, products, client types, jurisdictions of operation, delivery channels, and the financial institutions it interacts with when delivering its services. Also covering the assessment of the effectiveness of existing controls and mitigations in place to determine the residual risk rating for both general ML/TF risks relevant to the most designated service providers/AML/CFT reporting entities and industry-specific ML/TF risks faced by online casinos as these apply to your business operations. Visit our AML/CTF Risk Assessment page for more information.
• Comprehensive AML/CTF Programs (aka "AML/CFT Programme" in some jurisdictions): When it comes to online casinos' anti-money laundering compliance, your AML/CFT program is a core document that details how your business complies with various compulsory AML/CFT obligations, covering:

• the initial and ongoing CDD and EDD processes
• verification methods and requirements for identity, address, and source of funds
• internal and external reporting
• ongoing due diligence
• transaction monitoring
• employee vetting and training
• PEP and sanctions screening, and more

Our online casinos' AML solution is about grounding your AML/CTF program in reality and developing it based on your circumstances, including:

• your AML/CFT Risk Assessment
• your available ML/TF systems and controls
• your available resources
• your compliance budget
• your AML/CTF compliance team's experience and size
• your stakeholders' interests
• your available AML technology and other relevant factors
• Further Information: Visit our AML/CTF Programs page for more information.

• Online Casinos' AML/CTF Procedures for Effective AML Compliance: Effective procedures are another core pillar of online casinos' AML/CTF compliance. This is why our solutions cover the development and enhancement of a detailed set of AML/CTF procedures and protocols to meet the distinct needs of your business, with a focus on effective AML risk management across various business processes and the online casinos' AML requirements as they apply to each step of your customer journey.
• AML Manuals and Guidelines: These are more detailed, practical resources that support the procedures by providing step-by-step instructions, specific reference points, and standards. Depending on your business size and complexity, we develop and enhance internal manuals and guidelines necessary for effective and efficient AML/CTF compliance. These include AML Operating Manuals, guiding materials, and guidelines that outline what to do for each process, step, or decision within your procedures.
• ML/TF Controls Mapping: Implementing controls based on your documented risks is another cornerstone of online casinos' anti-money laundering compliance. We help you develop, map, and assess your internal ML/TF controls and improve their effectiveness to ensure compliance with online casinos' AML requirements, address specific financial crime, money laundering, and terrorist financing trends, and respond to any findings from internal and external AML/CFT auditors and supervisors.
• AML Red Flag Identification and Response Protocols: This is another area where a well-written AML policy or program must face the reality of operational speed, the workload across different teams, available tools, client base size, and other factors. That is why another part of our online casinos' AML/CFT solution focuses on developing clear guidelines for identifying and responding to red flags indicative of fraud, money laundering, or terrorist financing activities, enabling you to take timely and appropriate action in different circumstances.
• AML/CTF Policy Update: Assisting with the review and enhancement of your core AML/CTF documents and operational procedures to reflect changes in your AML policies, including those caused by:

• updates in the AML/CTF laws, online casinos' AML regulations or AML supervisors' sector guidance
• internal changes in your business structure, size, and resources
• the launch of new products or expansion to new jurisdictions
• changes in your risk appetite
• changes in related obligations, such as privacy laws, information sharing, online casinos' fraud prevention requirements, and more
• AML/CFT issues identified during internal or external reviews or audits
• other relevant factors

 

AML/CFT Technology Integration Support

Streamlining AML Compliance: Our online casinos' AML solutions include needs assessment and assistance in selecting and integrating appropriate AML technologies for efficient online casinos' anti-money laundering compliance management. This includes AML compliance technologies and tools that cover:

• Customer Due Diligence Automation
• E-KYC and Online Identity Verification
• Customer Onboarding Streamlining
• PEP and Sanctions Screening
• Ultimate Beneficial Owner (UBO) identification,
• KYB Solutions and AML/CFT Risk Management
• AML Alert Management
• Ongoing Due Diligence Obligations Management
• Internal AML/CFT reporting
• Online Casinos' Fraud Prevention
• AML/CFT Incident Management
• Exception Escalation and Management
• Online Casinos' AML/CFT Obligations for External Reporting
• AML/CFT Management Automation: Including automated response workflows and AI technology
• Customisable AML/CFT measures specific to onboarding and monitoring of your high ML/TF risk clients
• Online Casinos' AML/CFT Obligations for Record-Keeping
• Transaction Monitoring and Surveillance: Including transaction monitoring tools to automate detection and response to online gambling money laundering and terrorist financing red flags
• Effective CRM for handling Online Casinos' AML requirements

 

Online Casinos’ AML/CFT Audit Solutions

Having over ten years of AML/CFT compliance experience, ranging from AML/CFT framework and controls development and testing to successful AML/CFT management and issues resolution for various reporting entities, gives us the necessary expertise and qualifications to be your AML/CFT auditors.

We offer two comprehensive AML/CFT audit options to review your compliance with online casinos' anti-money laundering obligations. These options are:

Statutory AML/CTF Audit Option: A comprehensive review of your existing AML/CTF framework to assess whether your business complies with AML/CTF standards and applicable obligations. We independently test your compliance with both local AML/CTF obligations and specific online casinos' AML requirements. These often include but are not limited to:

• adherence to your AML/CTF risk assessment and operational AML/CFT procedures, including the existence of controls and mitigations to address money laundering and terrorist financing risks identified in your risk assessment
• compliance with your core AML/CFT documents, including sample testing
• your CDD requirements
• your staff vetting requirements
• your AML/CFT management processes
• your client onboarding and offboarding processes
• your EDD requirements, including source of wealth (SOW) and source of funds (SOF) requirements and application of the risk-based approach to different ML/TF risk levels
• your transaction monitoring process, covering large, complex, and unusual transactions and patterns
• your ODD processes
• your record-keeping process
• your suspicious matter reporting process (also known as "suspicious activity" or "suspicious transaction" reporting in some jurisdictions)
• your other reportable transactions process (typically covering cash and cross-border transactions)
• the way you detect and address material changes in client relationships
• your initial and ongoing screening process
• and other obligations for online casinos' AML/CFT compliance

Assurance Levels: Our statutory AML/CFT audit options are available as both:

• A limited assurance audit
• A reasonable assurance audit

Further Information: Please visit our AML/CFT Audit page for more information.

Internal AML/CFT Audit Option: Apart from an independent statutory audit, we also offer an internal AML audit option to prepare online casinos for an external audit by an independent auditor, an AML/CTF supervisor's review, or a review by another significant business stakeholder, such as a banking partner or an equity purchaser. This option is also suitable for significant business events like reorganisation or expansion.

Here, we go beyond merely meeting online casinos' AML requirements and focus on evaluating the effectiveness of your AML/CFT controls and ML/TF risk management processes for alignment with:

• the ML/TF risks faced by your business, including your Know Your Business (KYB) analysis
• Online casinos' anti-money laundering compliance obligations
• your current and future goals
• your business model
• your current and prospective client inflow
• the specific AML/CFT compliance areas or requirements (this process can be tailored to address particular AML issues or compliance areas, ensuring a targeted approach to online casinos' anti-money laundering compliance)

We help you not only identify any gaps and weaknesses but also provide insights on how to enhance your controls and respond to these in a commercially oriented manner for smarter AML/CFT compliance. Please visit our Internal AML/CFT Review Solution page for more information.

 

AML/CFT audit-related solutions:

• Post-Audit Remediation Support: We assist with implementing post-audit remediation actions, addressing and resolving any identified AML/CFT issues.
• AML/CFT Attestation Support: Our online casinos' AML solutions include helping you prepare the required attestations for your AML/CFT supervisor and other stakeholders. This involves confirming that all necessary remedial actions have been completed and that adequate AML/CFT compliance measures have been put in place.
• Post-Audit Stakeholders' Liaison: We manage your communications with national AML/CTF supervisors, banks, auditors, insurers, and other stakeholders, ensuring smooth progress in reporting on the status and completion of your post-audit action plan.

 

Online Casinos’ Fraud Prevention Solutions

The online casinos' anti-money laundering control environment is closely related to prevention of financial crime in general, and fraud prevention in particular. Online casinos' fraud prevention controls and ML/TF controls can form a unified compliance management framework tailored to the specific ML/TF and fraud risks your business is facing or is likely to face. Our Online Casinos' Fraud Prevention Solutions include:

• Fraud Risk Assessment and Analysis: Conducting assessments to identify and prioritise fraud risks across your operations, allowing you to allocate resources effectively.
• Incident Response and Investigation: Creating response plans to manage fraud incidents, including guidelines for investigating, documenting, and applying corrective actions to minimise potential damage.
• Implementing Preventive Measures: Setting up checks, alerts, and controls to tackle fraud risks in the online gambling, as well as drafting a set of procedures and guidelines to address fraud scenarios that you are likely to face or have faced.
• Data Analytics for Fraud Detection: Leveraging data analytics to identify focus points for your fraud prevention efforts and areas for improvement.
• Fraud Detection Technology Implementation: Choosing and helping you implement appropriate technology for real-time fraud detection.
• Fraud Awareness Training: Educating staff about fraud risks, including identity theft and impersonation.
• Further information: Please visit our Fraud Management Solutions page for more information.

Online Casinos' Fraud Response Requirements: In the current risk and compliance environment, implementing fraud prevention measures is either already mandated by law in some jurisdictions or, at minimum, expected by government agencies, financial market participants, and other stakeholders

 

Broader Risk & Compliance Solutions for Online Casinos

Your AML/CFT compliance is generally more effective when the right hand knows what the left hand is doing, and at the very least, they do not interfere with each other. Incorporating your controls and procedures for compliance with the online casinos' AML requirements into an overall risk and compliance management framework efficiently can increase your overall risk compliance effectiveness. This is where our experience can help you. Apart from AML/CFT compliance solutions for online casinos, we include the following risk and compliance solutions:

• Compliance Advisory and Management: A comprehensive set of solutions for second-line compliance management, including both compliance advisory and compliance management options. Visit our Compliance Solutions page for Online Casinos for more information.
• Third-line Compliance Assurance: A range of third-line compliance defence solutions covering compliance assurance program development and implementation, internal controls design, and controls testing solutions
• ISO Standards Compliance: A range of solutions for compliance with the International Organization for Standardization (ISO) standards, helping you prepare for ISO certification
• FATCA and CRS Compliance: A comprehensive set of solutions for complying with the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) requirements, including tax residency verification, ongoing due diligence, reporting, and record-keeping
• Privacy Law Compliance: A range of solutions covering development, implementation, and testing of data privacy controls, procedures, and tools required to meet the applicable obligations under the Privacy Act, the GDPR, ISO 27701, etc.
• Financial Licensing and Registration: A set of financial licensing solutions for online casinos, including preparation, licensing process management, regulator liaison, and post-licensing support in:

• Offshore financial centres and tax havens
• Singapore
• The United Kingdom
• The United States
• Australia
• New Zealand
• The European Union

 

Common Money Laundering Risks for Online Casinos

Online gambling money laundering risk types can be broadly classified into five categories:

• Product types (services offered)
• Delivery methods
• Customer types
• The institutions involved in delivering your services
• Jurisdictions of operation

Given the variety of products offered by different businesses, as well as their different business structures and operations, the examples below of money laundering risks faced by online casinos represent only a sample and are not exhaustive.

 

Product-Related Risks and Online Casinos’ AML Compliance

Some of the product-related ML/TF risks relevant to online casinos' anti-money laundering compliance include:

• Legitimisation of Gambling Winnings as  Source of Wealth: Lack of measures to detect and investigate accounts used to legitimise illicit funds by claiming gambling winnings without substantial betting activity (online betting platforms, sportsbook operators).
• Exploitation of Gambling Accounts for Non-Gambling Transactions: Insufficient controls to identify accounts misused for cross-border money transfers, tax evasion, or avoiding foreign currency obligations, particularly where funds are paid to third parties or withdrawn through non-traditional methods, such as cryptocurrency (virtual currency gambling sites, online payment platforms).
• Weak Monitoring of Large Winnings with Minimal Gambling Activity: Failure to scrutinise significant payouts or winnings generated by accounts with minimal gambling activity, increasing vulnerabilities for money laundering (poker rooms, casino game providers).
• Vulnerabilities in Virtual Currency Gambling: Lack of effective transaction monitoring for platforms accepting cryptocurrency, particularly in identifying wallet-to-wallet transfers or layering attempts using anonymous or pseudonymous digital assets (virtual currency gambling sites, cryptocurrency exchanges).
• Use of Gambling Platforms for Layering Funds Across Multiple Accounts: Weak controls to detect funds being layered through multiple accounts under the same or affiliated users to obscure their origin (online betting platforms, mobile gambling applications).
• Insufficient Oversight of High-Value Players in VIP Programs: Lack of measures to apply enhanced due diligence (EDD) on high-rollers or VIP clients, particularly where funds deposited and withdrawn exceed thresholds of typical gambling activity (casino game providers, sportsbook operators).
• Integration of Gambling with Prepaid Cards or Linked Wallets: Absence of controls to verify and monitor transactions involving linked wallets or prepaid cards, which may facilitate unmonitored fund transfers or obfuscate the origin of funds (prepaid card issuers, mobile gambling applications).
• Failure to Detect Rapid Withdrawals Post-Deposit: Insufficient monitoring to flag accounts where large deposits are immediately withdrawn without engaging in substantial gambling activity (online betting platforms, sportsbook operators).
• Misuse of Bonuses and Promotions: Lack of verification processes for promotional offers and bonuses, which may allow layering or integration of illicit funds through repeated use of incentives (online casinos, eSports betting sites).
• Affiliate Program Fraud: Weak oversight of affiliate payouts allows obscuring of illicit funds' origin, particularly where affiliate programs operate cross-border or without sufficient documentation (all types of gambling providers using affiliate marketing programs).
• In-Game Currency and Asset Transfers: Insufficient controls to monitor the movement of in-game currencies or virtual assets, enabling layering and obfuscation of illicit funds (virtual currency gambling sites, eSports betting sites).
• High-Volume, Low-Value Betting Patterns: Absence of transaction monitoring for frequent, small-value bets can obscure the aggregation and layering of funds by illicit actors (sportsbook operators, eSports betting sites).

 

Jurisdictional Risks and Online Casinos’ AML Compliance

Some of the jurisdictional risks relevant to online gambling money laundering prevention include:

• Failure to Detect Transactions Involving High-Risk Jurisdictions: Lack of controls to monitor and flag gambling-related transactions tied to jurisdictions with weak AML/CFT oversight, corruption, or significant organised crime activities.
• Insufficient Verification of Source of Wealth (SoW) and Source of Funds (SoF): Absence of measures to scrutinise SoW and SoF for winnings or deposits originating from higher ML/TF risk jurisdictions or tax haven countries, especially where funds are withdrawn to third-party accounts or offshore entities.
• Weak Assessment of Risks Associated with Offshore Gambling Operators: Online casinos partnering with unregulated or lightly regulated gambling operators in offshore jurisdictions may fail to address jurisdictional risks tied to tax evasion, capital flight, or organised crime connections.
• Inadequate Risk Assessment for Capital Flight-Prone Jurisdictions: Transactions involving players from jurisdictions with high levels of capital flight may lack effective monitoring. This risk arises when gambling accounts are used as conduits to move funds offshore under the guise of legitimate winnings or deposits.
• Inadequate Measures for Cross-Border Transactions: Lack of tailored controls for cross-border gambling transactions, particularly those involving digital wallets or cryptocurrencies, increases exposure to ML/TF risks from international jurisdictions with varying compliance standards.

 

 

Delivery Method Risks and Online Casinos’ AML Compliance:

Some of the delivery method-related ML/TF risks relevant to online casinos' anti-money laundering compliance include:

• Remote Onboarding Without Effective EKYC Measures: Failure to implement effective systems to link client-provided documentation with verified identities during remote onboarding processes.
• Inadequate Security Measures for Mobile Applications: Insufficient safeguards for mobile gambling applications enable unauthorised access and exploitation for ML/TF purposes.
• Inadequate Screening for Transactions Through Informal Money Networks: Lack of mechanisms to detect remittances routed via informal value transfer systems (IVTS), such as hawala networks.
• Vulnerabilities with Third-Party Payment Processors: Reliance on payment processors without AML compliance standards introduces ML vulnerabilities, particularly in cross-border transactions.
• Failure to Monitor Customer Communication Channels: Inadequate oversight of customer support and communication platforms may allow users to coordinate fraudulent schemes or bypass AML measures undetected.
• Weak transaction monitoring System: Lack of specific transaction monitoring controls for detecting large, complex and unusual transactions.
• User Location and Identity Misrepresentation: Absence of robust controls to detect VPN, proxy use, or false identity submissions enables users to mask their true location or identity, facilitating transactions from higher-risk jurisdictions.
• Weak Ongoing Due Diligence and KYC Refresh: Insufficient processes to regularly update and review customer profiles and KYC information, allowing outdated data to facilitate undetected illicit activities.

 

Customer Type Risks and E-money Institutions’ AML Compliance:

Some of the customer type-related ML/TF risks relevant to electronic money laundering prevention include:

• Multiple Account Creation and Misuse: Failure to implement systems to detect and flag duplicate or suspicious accounts enables layering of funds through small transactions across multiple accounts.
• Non-Resident Clients from Higher ML/TF Risk Jurisdictions: Insufficient due diligence measures to verify the legitimacy of funds and source of wealth for non-resident customers linked to higher ML/TF risk jurisdictions, particularly those attempting to bypass foreign currency control laws, tax laws, or AML oversight.
• Clients Using Nominees or Intermediaries Without Transparency: Lack of controls to identify and scrutinise accounts or transactions operated through nominees, intermediaries, or proxies to obscure beneficial ownership or evade compliance requirements.
• Weak Controls for Accounts Available to Vulnerable Groups: Absence of tailored measures to effectively apply customer due diligence (CDD) for users at higher risk of exploitation, such as young users, elderly clients, or individuals on welfare payments. This includes the need to detect indicators of scams or money mule activity.
• Corporate Clients With Beneficial Ownership Risks: Failure to adequately verify and monitor beneficial ownership of corporate or institutional accounts linked to gambling platforms allows funds to be misused for layering or tax evasion schemes. This risk is particularly significant when accounts are used to hold gambling winnings or large deposits, which can later be withdrawn to unrelated third parties in offshore jurisdictions, bypassing AML scrutiny.

 

Institutional Risks and E-money Institutions’ AML Compliance

Some of the institutional ML/TF risks relevant to e-money institutions' anti-money laundering compliance include:

• Delegation of Onboarding to Third Parties Without Oversight: Failure to monitor and enforce AML/CFT compliance standards among third-party agents or affiliates conducting customer onboarding.
• Engagement with Unregulated Financial Entities: Lack of controls to assess and mitigate risks when partnering with unregulated investment platforms, external payment processors, or informal networks (cryptocurrency-based gambling platforms and virtual currency gambling sites).
• Absence of Screening for Adverse Media on Partner Institutions: Inadequate mechanisms to monitor adverse media coverage related to financial crimes or compliance failures in partner institutions.
• Failure to Mitigate Risks Linked to Gatekeeper Professionals: Lack of controls to detect and address risks posed by gatekeeper professionals, such as accountants or lawyers, acting as intermediaries or using client trust accounts to facilitate transactions (high-stakes gambling platforms).

 

Standard Anti-Money Laundering Requirements for Online Casinos

Given the variety of online casinos' AML obligations, this list is not exhaustive:

• Conducting customer due diligence, including appropriate KYC checks: Ensuring verification of customers' identities, as well as identities of beneficial owners of customers that are legal entities.
• Conducting transaction monitoring: Monitoring deposits, withdrawals, and other transactions to identify and report suspicious transactions and patterns.
• ODD requirements: Conducting ongoing customer due diligence, which is generally based on the customers' ML/TF risk profiles and ML/TF risk categories, as well as changes in their activities, behaviours, or risk factors.
• Staff Vetting: Performing comprehensive background checks and ongoing vetting of staff to maintain high standards of integrity and awareness.
• Reporting Certain Non-Suspicious Transactions: Obligation to report cross-border or cash transactions over a certain threshold, as per the local AML/CFT regulations, in a timely manner. However, if the transaction is processed through a local bank or another reporting entity, reporting requirements may depend on the local AML/CFT regulatory interpretation.
• Compliance with the regulatory obligations: Including registering with your local AML/CTF supervisor, appointing an AML/CTF officer or an MLRO, answering requests for information from the police, regulators and your AML/CTF supervisor, filing an annual report and more.
• Regular Staff Training: Providing continuous training to ensure employees are aware of AML/CFT protocols and can recognise red flags.
• Timely Reporting of Suspicious Transactions: Ensuring that suspicious transactions and activities are reported to the relevant authority (either your local AML/CFT supervisor or a financial intelligence unit (FIU)) within the required deadlines.
• ML/TF Risk Assessments: Conducting regular assessments of ML/TF risks faced by your business is a part of AML risk management for online casinos and online gambling outlets.
• Independent AML/CFT Audits and Online Casinos: Organising periodic independent reviews of the AML/CFT program, other core documents, and components of your AML/CFT framework to assess their existence, compliance, application, and, where applicable, effectiveness, depending on local AML/CFT audit guidance.
• Applying EDD measures: Conducting enhanced due diligence on certain customers and certain transaction types.
• Establishing Clear AML/CFT Policies and Procedures: Creating documented guidelines for staff to follow.
• Monitoring PEPs and Sanctioned Entities: Implementing measures for additional scrutiny of politically exposed persons and entities on sanction lists.
• Screening Against Watchlists: Regular checks of clients against domestic and international watchlists.
• Ensuring Proper Record-Keeping: Maintaining detailed and accurate records of client information and transactions in compliance with AML/CFT regulations.

 

Common Online Casinos’ AML/CFT Issues

This is not an exhaustive list and could include:

During Customer Onboarding

• Inconsistent Application of Risk-Based Measures: Insufficient tailoring of AML/CFT measures during onboarding, leading to gaps in addressing product-specific, jurisdictional, and customer risks.
• Overreliance on Automated Systems Without Manual Oversight: Dependence on automated verification tools without manual review processes to detect false positives or overlooked red flags.
• Inadequate Verification of Beneficial Ownership: Failure to identify beneficial owners, particularly for accounts tied to corporate or high-risk clients.
• Acceptance of Incomplete or Falsified Documentation: Onboarding clients without verifying all necessary information, such as source of funds, source of wealth, or identity documentation.
• Failure to Conduct Adequate Risk Assessments: Inadequate ML/TF risk assessment for customers' risk coupled with ineffective application of tailored AML/CFT measures across the customer  base. For example to customers  from vulnerable groups, complex entities, and offshore tax haven-based clients.

 

After Customer Onboarding

• Weak Transaction Monitoring Systems: Inadequate systems for detecting unusual or suspicious activities, such as ineffective thresholds and poorly defined monitoring scenarios.
• Failure to Maintain and Update AML Technology: Lack of ongoing updates and maintenance of AML compliance technology hinders the ability to detect evolving ML/TF patterns, particularly as typologies shift in response to regulatory advancements and enforcement trends.
• Failure to Update Customer Risk Profiles: Lack of processes to update customer information and reassess risk profiles regularly, leading to outdated assessments.
• Ineffective Cross-Border Transaction Monitoring: Insufficient scrutiny of international transactions, particularly involving higher ML/TF risk jurisdictions or unverified third parties.
• Inadequate Ongoing Customer Due Diligence (OCDD): Neglecting to review ongoing customer activities, failing to identify changes in behaviour, or missing new risk indicators.
• Lack of Integration with Risk-Based Frameworks: Failure to link ongoing transaction monitoring and reviews to initial risk assessments, resulting in blind spots in detecting higher-risk activities.
• Inadequate Staff Training: Insufficient training on AML/CTF policies and procedures, resulting in weak understanding and implementation of compliance requirements.
• Deficient Governance and Oversight: Senior management not prioritising AML/CTF compliance programs, leading to resource constraints and weak institutional commitment.
• Cybersecurity Weaknesses Impacting AML Measures: Insufficient cybersecurity protections expose online casinos to risks such as data breaches and unauthorised access to sensitive customer information, undermining the effectiveness of AML systems reliant on secure and accurate data.

 

 

 

Common Online Casinos’ Fraud Risks

The following list of online casinos' fraud types is not exhaustive:

• Online Casinos and Identity Fraud: Involving identity theft or impersonation to create accounts, access systems, or conduct unauthorised transactions under false identities.
• Online Casinos and General Transaction Fraud: Fraudulent activities using manipulated, counterfeit, or stolen documentation to execute unauthorised deposits, withdrawals, or payments.
• Online Casinos and Cross-Border Fraud: Fraud involving international transactions, such as layering funds through multi-jurisdictional accounts or creating fictitious entities in offshore jurisdictions (offshore gambling platforms, global betting providers).
• Online Casinos and Insider Fraud: Employees or contractors exploiting access to systems or sensitive data for unauthorised fund transfers, data leaks, or tampering with player accounts.
• Online Casinos and Phishing Fraud: Cybercriminals targeting customers of online casinos through phishing emails or messages to obtain login credentials or sensitive financial information.
• Online Casinos and Technology Fraud: Exploitation of vulnerabilities in online gambling platforms, including manipulation of APIs, hacking of payment gateways, or tampering with user interfaces (virtual currency gambling sites, mobile gambling applications).
• Online Casinos and Bonus Abuse Fraud: Exploitation of promotional offers, such as bonuses or free bets, using multiple accounts or fake identities to illegitimately gain funds.
• Online Casinos and Digital Asset Fraud: Unauthorised access to or manipulation of cryptocurrency wallets, crypto-to-fiat payment systems, or blockchain transactions for fraudulent activities (virtual currency gambling sites, cryptocurrency-based casinos).
• Online Casinos and Third-Party Payment Fraud: Unverified or unauthorised third-party transactions, including layering of funds through unrelated intermediary accounts or payment facilitators.
• Online Casinos and Account Takeover Fraud: Fraud involving unauthorised access to customer accounts through compromised credentials, allowing perpetrators to place bets, withdraw funds, or alter account settings undetected (consumer-focused gambling platforms, mobile gambling applications).
• Online Casinos and Money Mule Fraud: Exploitation of vulnerable individuals to create gambling accounts and process illicit funds as winnings, disguising the origin of funds.

 

 

Common AML/CTF Red Flags for Online Gambling Providers

The Financial Action Task Force (FATF) and various national AML/CTF supervisors highlight the following non-exhaustive list of ML/TF red flags relevant to online gambling money laundering prevention:

• Unusual Account Funding Patterns: Large deposits inconsistent with a customer's known profile or declared source of funds, especially when tied to offshore accounts or cryptocurrency wallets.
• Frequent Withdrawals Without Gambling Activity: Regular account withdrawals not justified by winnings or gambling behaviour, often involving third-party payouts or anonymous payment methods.
• Transactions Linked to High-Risk Jurisdictions: Gambling transactions originating from or paid out to jurisdictions with weak AML/CFT controls or associated with offshore banking and tax evasion.
• Use of Multiple Accounts: Creation of multiple user accounts to distribute deposits and winnings, enabling layering of funds to obscure their origin.
• Suspicious Use of Bonuses and Promotions: Exploitation of bonuses or promotional offers to transfer funds between accounts or create the appearance of gambling activity.
• Cross-Border Payments Lacking Clear Rationale: International transactions without apparent economic or personal justification, including payments to unrelated third parties.
• Inconsistent Cryptocurrency Transactions: Deposits or withdrawals involving cryptocurrencies with unusual patterns, such as high-frequency transfers to external wallets or exchanges without identifiable links to gambling activity.
• Rapid Account Turnover: High volumes of deposits and withdrawals in a short time frame, with minimal or no gambling activity.
• Unverified Beneficial Ownership for Corporate Accounts: Corporate accounts with opaque structures, unverified beneficial ownership, or ties to high-risk jurisdictions.
• Frequent Payouts to Third Parties: Account withdrawals directed to third parties not associated with the account holder or gambling activity.
• Anomalous Bets or Wagering Patterns: Bets that deviate significantly from normal gambling behaviour, such as high-value, low-odds bets repeated over a short time.
• User Location and Identity Misrepresentation: Use of VPNs, proxies, or false identity documentation to mask the user's true location or bypass geographic AML/CFT restrictions.
• Transactions Without Apparent Gambling Activity: Deposits and withdrawals routed through gambling accounts without evidence of actual wagering or gaming.
• Rapid Growth in Gambling Activity: Sudden, unexplained spikes in gambling activity, particularly from users newly registered or tied to high-risk jurisdictions.
• Exploitation of Virtual In-Game Currencies: Transfers of in-game credits or virtual gambling assets that can be redeemed for real-world currency without sufficient oversight.
• Use of Informal Value Transfer Systems (IVTS): Payments routed through informal networks such as hawala to bypass AML/CFT oversight, particularly in cross-border scenarios.