Money launderers amass dirty money through illegitimate means and convert it into clean money by buying assets, such as real estate, cars etc. Casinos have always been an easy target for money launderers because of the nature of their services and products. Gambling provides a money launderer the luxury of anonymity, choice of cash transactions, and accessibility to multiple premises ― making the masking of the illegitimate money trail a breeze.

However, there are many ways by which casino managers can keep money launderers at bay. To ensure they follow strict procedures to stymie the rise of these criminals, under the MLR 2017, they have been legally obligated to follow these guidelines.

  •         A thorough risk assessment needs to be done on a frequent basis and adequate safeguards must be placed to mitigate the risks this assessment yields. The risk assessment should not leave out critical issues, such as customer portfolio, remote sites, history of money laundering cases and surveillance in the casino premises.
  •         Identify money laundering risks, based on an in-depth and revised risk assessment and devise policies and procedures to tackle them. Ensure that every member of the staff is apprised of these policies and procedures and properly trained.
  •         Senior management must take significant responsibility in making and maintaining procedures and controls to ensure that the risks identified through a comprehensive risk assessment are properly managed.
  •         Archives of all money laundering policies, cases, procedures and all financial transactions with customers must be safely kept to ensure total transparency.  CDD identification and verification record must also be kept for a minimum of 5 years.
  •         If any sort of suspicious activity is observed on the gambling grounds, a prompt report must be provided to the authorities. The staff must be properly trained to identify attempted money laundering incidents.
  •         Performing customer due-diligence investigation which involves verifying the identity of the customers involved in high level transactions.
  •         Assessing these transactions and sending out their reports to concerned authorities, if any suspicious activity is registered.
  •         Encouraging the use of international credit cards, debit cards instead of cash transactions which are harder to trace.
  •         Checking the financial assets of a player to measure risk


Preventing the access of minors in gambling grounds

Setting foot on casinos is taboo for anyone under the age of 19 in many countries. Authorities should take full responsibility to ensure that numerous measures are in place to uphold this prohibition. Casinos deal with minors by employing the following strategies.

  •         Security staff positioned at every entrance to verify the identification of each customer.
  •         ID scanning equipment to verify age.
  •         Staff training
  •         Informing the youth of the hazards of gambling and creating awareness onsite.

The staff’s training holds paramount importance. Trained investigators are stationed to oversee the performance of the security staff. The recruitment process of the casino staff is sophisticated. In order to be a casino gaming floor staff, one has to forego anti-money laundering training before taking control of a particular gaming station. This training equips them to understand their obligations, and promptly spot and repot any suspicious activity on the gambling grounds.

The need for Responsible Gambling

Also, this training helps staffers comprehend the profound meaning of responsible gambling and what it entails. It makes them aware of the possible hazards that arise as a result of problem gambling. It also gives them information about the resources being provided to players and families for responsible gambling.

Reporting Terrorist Financing Transactions

Any kind of money that has been allegedly gained through terrorist activities is not accepted by casinos. Casinos have been directed to file terrorist activity reports if they believe that the gambling money is obtained from terrorist activities. When Lottery corporations find out from a source that the property in its possession or control belongs to a terrorist group, they promptly alert the authorities.

In the past, gambling activities have caused massive troubles to both the casinos and the authorities. That is why there is a pressing need to follow the strict regulations imposed upon by the authorities on casinos to curb the rise of terrorism and suspicious financial activity. Casino must comply and provision their resources to ensure that responsible gambling is practiced on casino grounds. In recent times, casinos have done their best to help the authorities, but further compliance is needed to completely uproot the evil of trouble gambling.

Sports’ betting involves placing wagers on the outcome of matches. If the predictions prove to be accurate, people who have placed these bets get rewards, in accordance with a preset odds formula. The primary intent behind money laundering is to use the profits obtained from illegal means in legitimate businesses, to mask the trail of money. What punters do is that they get large sums of illegal money from sports betting, and then make it seem as if these profits have been derived from legitimate sources.

Punters employ certain Machiavellian schemes to launder money. They introduce illegitimate wealth in the financial system ensued by making perplexing financial transactions to befuddle authorities. Finally, they increase their profits from the investment of illegal monies in legitimate businesses. It’s a well-structured scheme that is employed to outwit the authorities, and that’s why it’s necessary to implement stern antimony laundering policies and practices to eradicate these foul practices.


Anti-Money Laundering Practices

  1. ·         The Money laundering act of 2001 should strongly deter the practice of money laundering in sports betting. It should clearly specify the maximum amount a single person can bet on a particular sport. Exceeding this limit must result in strict penalties. It behooves the sports betting supervisor to report any individual who does not adhere to these limitations.
  2. ·         Licenses must be provided to sports betting administrators before they launch their businesses. If they fail to obtain necessary certifications, they should not be permitted to open up a sports betting center. Moreover, a sports betting company must maintain a certain level of transparency to ensure any illegal or suspicious activity doesn’t slip under the radar.
  3. ·         A well-detailed monthly or a quarterly review of all bets placed should be handed out to the commission. The commission should scrutinize the affairs of a sports betting business to ensure that it is does not abet punters in money laundering. If found guilty, hefty fines and criminal sentences should be given to the handlers of the business.
  4. ·         Wagers placed in the thousands and millions should be not paid in cash. Instead, punters must be forced to place hefty wagers through banks, so that their gambling activity can be traced.
  5. ·         Authorities must not simply regulate sports betting activities. They should also play a vital role in ceasing the access of money launders to the sports betting industry. This can only happen if strict laws are imposed and implemented to kill the emergence of money launderers in their wake. It must make them think long and hard, before they commit money laundering of any magnitude.
  6. ·         Sports betting businesses must also play their part in halting the rise of money launderers. They should effectively cooperate with judicial and law enforcement authorities to open the curtains on these unlawful activities that are funding terrorism and other kinds of crime.
  7. ·         Sports’ betting is a virtual business and grants punters with virtual anonymity, which makes it easier for them to carry out suspicious money laundering activities. This anonymity should be taken away from them in order to keep a close eye on their gambling habits. They should not be allowed to open anonymous accounts, or accounts under made up aliases. They should be strictly ordered to show their true identities before indulging in gambling activities of any sort.
  8. ·         Direct acquisition of funds from players in the form cash should also be discouraged. Any sort of financial transactions should be made through credible payment methods, such as credit cards, electronic transfer, cheques. This will help authorities trace the money trail, and eliminate any doubts regarding suspicious money laundering activities.
  9. ·         A punter should be allowed to register only one account under his real name. A punter possessing several accounts can easily fool the authorities.
  10. ·         Before placing a wager, the sports betting managers should make sure that the account from which the wager has been placed has adequate funds to come good on the bet.
  11. ·         Prohibit users from establishing gambling profiles from disreputable states or territories.
  12. ·         If a user account has no gambling activity for an extended period, deactivate his account, and send his pending balance back to him.
  13. ·         If possible, gather information from external sources about the financial history of the play before signing him up.

All these anti-money laundering practices can uproot the existence of dubious players in the sports betting business, and make it a seamless experience for people who are in the world of  sports betting for all the right reasons.

Hong Kong and Kuala Lumpur: 8 March 2010. The Society of Anti Money Laundering Professionals has launched a new class of membership. For this class, there is no annual membership fee for 2010.

The Society of Anti Money Laundering Professionals has introduced a new grade of membership for those who do not qualify as Associate Members. The new Affiliated members scheme has no annual fee for 2010.

The Society is in its grandfathering phase and therefore admission to the Society is based upon demonstrable experience. However, for those who are just starting out on their path as a counter-money laundering compliance and risk professional, their lack, or relative lack, of expertise has been a bar to membership.

The new Affiliated Member is has been introduced so that those with less than two years' relevant experience can nevertheless gain the advantages of membership.

The new Affiliated Member grade will have an annual membership fee - but for members joining in 2010, that fee is waived. There is a joining fee, paid on admission, which is not waived.

Affiliated members are permitted to remain at that level for a maximum of two years. During that time, they must achieve the qualification criteria for Associate Member and, at the end of the membership year in which they achieve those qualification criteria, must enrol as Associate Members, or terminate their membership.

The Society of Anti Money Laundering Professionals is part of The Anti Money Laundering Network, an international group of companies.

Qualifying criteria:

Any person who has been working in any of the following roles immediately prior to the making of the application for a period of less than two years:

a. compliance, risk management or internal audit of a registered financial institution or other organisation required to comply with regulations made under laws to combat money laundering and terrorist financing; or

b. the drafting of legislation or regulations applicable to counter-money laundering and anti-terrorist financing; or

c. the following government roles; or

- financial crimes investigation in a police, customs or regulatory environment; or

- intelligence agency including FIU or internal or external security service; or

d. internal audit in a commercial organisation or NGO.

Note: internal general management or consulting such as HR, training, IT are not eligible for this class of membership and should apply to be a consultant member.

For information on other grades of membership, see About the Society (left column)