Vulnerabilities of Casinos and Gaming Sector

The vulnerability of casinos for money laundering (ML) and terrorist financing (TF) was recognised in the revision of the FATF 40 Recommendations, with obligations on casinos being significantly enhanced. However, there remained a lack of recent regional or global identification of ML/TF threats on casinos and gaming, which this report seeks to address. 

The report considers vulnerabilities from gaps in domestic implementation of anti-money laundering / combating the financing of terrorism (AML/CFT) measures and discusses a number of policy implications.  It identifies significant ML vulnerabilities and related case studies and typologies, but does not identify any instances of TF through the sector

Overall, there is significant global casino activity that is cash intensive, competitive in its growth and vulnerable to criminal exploitation. This paper identifies:

• significant gaps in awareness of ML threats (typologies)
• gaps in regulatory and law enforcement responses
• gaps in online gaming typologies 
• issues with controls over junkets / VIP programs
• significant issues with controls over ‘high seas’ gaming. 
• significant gaps in global coverage of AML/CFT controls over the sector, which represents a significant vulnerability.

This APG/FATF report considers casinos with a physical presence, online gaming and illegal gambling are beyond the scope of this study.