• Casino Money Laundering Reddit Sites
• Money Laundering Through Casinos
• Casino Money Laundering Reddit Websites

There are several key methods that criminals deploy when money laundering. Many groups rely on breaking up the deposits into small tranches to avoid flagging in a practice known as structuring. Others simply buy chips with cash, spend some time on the casino floor and attempt to cash them out as winnings. There are many methods that involve the use of shell companies to conceal transactions, bank accounts and individuals involved. It is an incredibly complex area of finance and one that the authorities are fighting tirelessly to stamp out in all forms.

Laundering money is done best in a business where people pay in cash. Casinos are almost entirely done in cash. Laundering money works best when you have enough customers coming in that no one could keep track of them all. Where you don't have an actual product that you give that you'd have to have bookkeeping for. Casinos have worked to lure wealthy Chinese gamblers to baccarat tables. But a case involving the Sands shows how ‘shill’ players help keep the money flowing.

1. When lawyers representing the casino operator told the NSW Casino Inquiry that there was a good chance criminals used the properties to launder money, it was a further nail in the coffin.
2. The growing case of Trump Money Laundering: multiple bankrupt casinos, multiple violations. Secret cash purchases of Trump property. 'We see a lot of money pouring in from Russia.' (Don Jr.) 'We don’t rely on American banks. We have all the funding we need out of Russia.' (Eric) - lots more.

What Makes Casinos the Perfect Target?

Casino gambling is a brilliant way to make money disappear, and reappear in separate bank accounts. Obviously, the casino industry takes measures to make this difficult which we will explain in more detail down the page. The casino does not necessarily need to be complicit in the money laundering activities for criminals to be successful, but many have known to be in the past. With so many underground markets operating throughout Asia, Europe and America – criminals have plenty of casinos and sports betting operators they can exploit to launder their dirty cash.

Without the compliance of the regulated casino industry, this is an uphill battle that the authorities cannot fight alone. There are many motivated, and well-funded criminal gangs that are persistent in their efforts to use casinos to launder money. Within the casinos, themselves exist many vulnerabilities that can be easily exploited. The staff in casinos represent one of the biggest risk factors for money laundering, as they are often low-paid administrative staff that can be easily bribed or threatened to assist the criminals laundering their money.

But what makes the casino money laundering so appealing rather than off-shore shell companies or other such methods.

The three biggest reasons for money laundering at casinos are:

• Casinos and sports betting operators have enormous cash flows that make it easy to bets intended for money laundering within the sea of transactions flowing in and out.
• It doesn’t matter who you are, whether you’ve been convicted of financial crimes or where your money comes from. The majority of casinos around the world are happy to accept wagers from anyone with hard cash to gamble.
• High-rollers are a major source of profit for many casinos – in order to maintain a strong a favorable relationship with the client, staff may ignore or turn a blind eye to any suspicious transaction.

As you can imagine from the above statements, revenue and profit are huge motivating factors for the casinos. It is difficult to deny that casinos are powerless to stop this activity, and certainly more needs to be done from industry regulators to enforce systematic checks on customers that set-off red flags with suspicious depositing activity.

Industry regulators certainly have a part to play, by scrutinizing large casino companies around the world they regularly audit and analyze financial statements looking for irregularities. The biggest operators make enough money from legal transactions, and it tends to be smaller casinos in less stringent jurisdictions that are complicit with money launderers. In Asia, there has been a long-term problem with this illegal activity – and a thriving underground gambling industry.

Things are a little different online, especially if you are gambling in the UK or another strictly regulated market. If you are worried about what might be going on at your favorite casino site, have a look at our guide to casino safety to see what reputable sites are doing to keep everything above board.

Fighting Against Money Laundering with Regulation

Within tightly regulated industries such as Europe and North America casino money laundering is a very low threat to operations. The regulators in these territories are very diligent, using a mixture of law enforcement integrations, technology, and correct procedures to mitigate the problems. Communities in Europe and North America are more resistant to the risks associated with exposing themselves to organized crime and are more active in their resistance to money launderers.

However, the Asian gambling industry is worth over $180bn annually. Before the market became such an enormous part of the local economy, a strong and thriving underground gambling scene was firmly established. Even now that big corporate casino interests have a firm hold on the market, the dark underbelly still remains.

Certain casinos within Asia are notorious for being connected to the criminal underworld – on a much larger scale than any European equivalent. It has been proven in the past that the Yakuza has a strong grip over many gambling operators in Japan, and in South-East Asia there have been several high-profile match-fixing and money laundering busts in the past decade.

The tide is turning though. Many of these casinos have begun enforcing identity checks on their new customers. More importantly, the range of payment options that was previously available has been refined to a select few, in this scenario payments are much more easily traced. The ability to use different accounts for deposits and withdrawals has enabled casino money laundering in the past, ending this practice will do a great deal for squashing the remnants of money laundering in this industry.

Is the Game Up for Money Launderers?

Obstructing the use of casinos as a vehicle for money laundering is a constant battle between law enforcement, criminals and casino operators. In the UK, customer check procedures are continuously improving, and in its current state, the system is highly impenetrable. The same rings true for much of Europe and North America. However, the lackluster approach to financial scrutiny in certain jurisdictions continues to allow the practice of money laundering to sneak under the radar. The amount of money involved is truly staggering, with that comes powerful and illicitly motivated groups who are determined for their business to go uninterrupted. The battle rages on between criminals and the authorities who are often left chasing shadows.

You can find out more info about how casinos stay safe from crime and how internet gambling is regulated in this section of our guide to real money casino gambling.

Second Part of a Two-Part Series

Casino Money Laundering Reddit Sites

As we blogged yesterday, British Columbia’s (“B.C.”) Attorney General David Eby recently released an independent and very detailed report examining money laundering in B.C.’s gaming industry and providing 48 recommendations to combat the problem. See Peter M. German, QC, Dirty Money: An Independent Review of Money Laundering in Lower Mainland Casinos conducted for the Attorney General of British Columbia (Mar. 31, 2018) (“German Report”). As we noted yesterday, when discussing the U.S. regulatory system, the German Report favorably cites the Nevada Gaming Commission and Nevada Gaming Control Board, whose Enforcement Division “acts as a first line of defence against organized crime and bulk cash buy-ins[,]” and further observes that the federal Financial Crimes Enforcement Network, “[i]n partnership with Internal Revenue Service, acts as the enforcement arm for most money laundering issues.”

The U.S.’s more robust, streamlined AML regulatory regime, although hardly perfect, stands in stark contrast to the dysfunction alleged in the German Report that plagues B.C.’s current framework. In this post, we describe the U.S. AML regulatory regime for the gaming industry, and the recent enforcement actions which it has produced. Although the pace of AML enforcement has been somewhat sporadic, it appears to be increasing over time in regards to the gaming industry. Certainly, attention by regulators — as well as by the industry itself — to AML/BSA compliance has increased over the last several years.

The U.S. AML Regulatory Framework for the Gaming Industry

Money Laundering Through Casinos

As a threshold matter, the Financial Crimes Enforcement Network (“FinCEN”) has authority to investigate casinos for compliance with and violations of the Bank Secrecy Act (“BSA”). FinCEN, in turn, has delegated to the Internal Revenue Service (“IRS”) its authority to examine casinos for compliance with the BSA. Under this framework, if the IRS identifies significant BSA violations during a casino examination, FinCEN initiates an investigation into that casino and, depending on the investigation’s outcome, may assess a civil penalty against the casino. As a result, the IRS and FinCEN work in conjunction while enjoying broad mandates that are not at odds with one another.

And, in contrast to the B.C. system described in the German Report, the U.S. has implemented more streamlined regulatory requirements for casinos pursuant to the Bank Secrecy Act (“BSA”), including:

• Filing suspicious activity reports (“SARs’) for suspicious transactions of at least $5,000;
• Filing currency transaction reports (“CTRs”) for cash ins or cash outs exceeding $10,000;
• Complying with certain recordkeeping requirements for up to five years, including a casino’s receipt of funds for each customer, bookkeeping entries for debits or credits into a customer’s casino account, and credit extensions exceeding $10,000; and
• Implementing AML compliance programs.

FinCEN issued guidance in 2010 regarding AML/BSA compliance programs in the gaming industry, stating that, “at a minimum,” such a program must include:

• A system of internal controls to assure ongoing compliance with the BSA;
• Internal or external independent testing for compliance with a scope and frequency commensurate with the risks of money laundering and terrorist financing posed by the products and services provided;
• Training of casino personnel, including training in the identification of unusual or suspicious transactions;
• An individual or individuals to assure day-to-day compliance with the BSA;
• Procedures for using all available information to determine and verify, when required, the name, address, social security or taxpayer identification number, and other identifying information for a person;
• Procedures for using all available information to determine the occurrence of any transactions or patterns of transactions required to be reported as suspicious;
• Procedures for using all available information to determine whether a record required under the BSA must be made and retained; and
• For casinos and card clubs with automated data processing systems, use of the programs to aid in assuring compliance.

Arguably, the gaming industry remains one of the last bastions of a major business that still often deals significantly in cash — in a world increasingly driven by technology and credit. To that end, some gaming businesses may attract a disproportionate share of customers seeking to avoid ensconced BSA reporting and record-keeping requirements, including the CTR filing requirement. Similar to some of the allegations in the German Report, some casinos also may attract certain individuals from across the globe who potentially are attempting to undermine certain laws in their home country, including tax reporting obligations.

Casino Money Laundering Reddit Websites

AML Enforcement and the Gaming Industry

In recent years, FinCEN has shown an increased focus on AML compliance in the gaming industry. It assessed only three civil penalties against casinos, for a total of $1.6 million, from 2003 to 2014. In contrast, it imposed approximately $110 million against casinos from 2015 through 2016 and has pursued four significant enforcement actions since 2016.

As we have blogged, FinCEN announced on May 3, 2018 that it imposed a $5 million civil monetary penalty against Artichoke Joe’s for the casino’s alleged deficiencies in its BSA compliance. FinCEN asserted that Artichoke Joe’s AML program failed to implement sufficient procedures to identify loan-sharking operations. It found that: (1) the club’s senior management admitted loan-sharking operations were commonplace and observed by employees; (2) the club failed to file SARs and CTRs in compliance with the BSA; and (3) the club failed to undertake an independent audit after illegal loan sharking was initially detected.

FinCEN also pursued three large enforcement actions in 2016, about which we have also blogged:

• Cantor Gaming: FinCEN assessed a $12 million civil penalty against Cantor Gaming for purportedly “egregious and systemic” AML compliance failures on October 3, 2016. It found that Cantor Gaming failed to (1) provide adequate AML training for its officers and employees; (2) use all available information to identify and report suspicious transactions; and (3) maintain adequate internal controls to detect money laundering.
• Hawaiian Gardens Casino: On July 15, 2016, FinCEN imposed a $2.8 million civil penalty against the casino for allegedly repeatedly violating its BSA requirements. FinCEN attributed these failures to the club’s lack of a compliance culture, emphasizing that: (1) its leadership failed to meet as required by its charter; (2) its leadership failed to review and approve its risk assessment; and (3) its management failed to implement policies and procedures for customer identification.
• Sparks Nugget: On April 5, 2016, FinCEN imposed a $1 million civil penalty against the company for purportedly engaging in willful and repeated AML violations. FinCEN alleged that: (1) the company’s committee for deciding whether to file SARs never actually met and it included members that did not know that they were on the committee; (2) the company prohibited its compliance managers from interacting with BSA examiners; and (3) the casino used customer information only to further its business interests and not to comply with the BSA.

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