A regulated service provided by licensed establishments or platforms, enabling individuals to participate in games of chance or place wagers for entertainment. This includes casino-style gambling (e.g., slot machines, electronic gaming machines, and table games), lotteries where participants purchase tickets for a chance to win prizes, online gambling platforms offering virtual casinos, poker rooms, sports betting, and the associated account management functions that enable deposits, withdrawals, and the purchase or redemption of chips or credits.
Main/
Gambling Services
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Code
PS0069
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Name
Gambling Services
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Version
1.0
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Category
Gambling & Gaming
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Created
2025-03-14
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Modified
2025-04-02
Related Techniques
- Mules deposit illicit proceeds as cash to purchase casino chips, often using multiple individuals to stay under threshold reporting limits.
- Chips are transferred among different patrons or exchanged for larger denominations and possibly different currencies, with little to no actual gambling.
- Rapid redemption of chips—often in the form of casino-issued checks—provides a veneer of legitimate gambling winnings that are then deposited into external accounts.
- Distributing these transactions across multiple mules makes it harder for authorities to link them to the illicit origins of the funds.
- Criminals set up online gambling accounts to deposit illicit proceeds in small increments, masking the true source under seemingly legitimate wagers.
- Minimal or hedged bets camouflage large fund flows, allowing quick withdrawals as “winnings,” thereby integrating illegal funds into the financial system.
- Unlicensed or lightly regulated platforms lacking robust KYC controls facilitate account creation with stolen or synthetic identities, increasing anonymity and obscuring cross-border transactions.
- Criminals insert illicit cash into slot or electronic gaming machines with little to no actual betting, generating TITO vouchers that appear as gambling proceeds.
- These vouchers can be exchanged among accomplices or consolidated and redeemed later, obscuring the transaction trail.
- Once redeemed, the proceeds are often deposited into financial institutions as purported 'gambling winnings,' completing a layer of laundering.
- Casinos provide an avenue for introducing bulk cash as alleged 'winnings.'
- Chips are purchased with illicit proceeds, then redeemed as legitimate payouts, obscuring the original source of smuggling money.
- Criminals establish or operate offshore-licensed gambling platforms in jurisdictions with lax oversight, allowing illicit funds to be commingled with legitimate betting proceeds.
- Minimal transparency and lax identity checks obscure the true origins of the funds, complicating AML detection.
- Criminals use counterfeit funds to purchase chips or bets, then cash out legitimate winnings.
- Poor currency screening at gambling venues allows phony bills to enter the payment cycle more discreetly.
- Criminals convert illicit proceeds into gaming chips and quickly cash out with minimal betting, effectively converting traceable deposits to untraceable currency.
- Casinos’ high volume of transactions provides cover for swift and opaque cash conversions.
- Criminals convert illicit funds into gaming chips or digital balances, then cash out as purported ‘winnings,’ making funds appear legitimate.
- Staff vulnerabilities or confederates may facilitate forged betting receipts, chip-dumping, or minimal net-loss betting schemes that disguise the true ownership and source of funds.
- Online platforms provide cross-border layering opportunities with limited face-to-face KYC, complicating AML oversight and tracking.
- Criminals purchase large volumes of lottery tickets using illicit proceeds, making these transactions appear as routine gambling activities.
- They may pay legitimate winners a premium to obtain winning tickets, then redeem the prizes themselves, effectively turning illegal funds into apparently lawful lottery earnings.
- By channeling winnings through front companies or third-party associates, they further obscure the link between the original illicit funds and the declared source of wealth, complicating AML efforts.
- Criminals place repeated, structured wagers below reporting thresholds, disguising bulk cash as routine bets and winnings.
- Collusive staff or manipulated recordkeeping can transform illicit funds into legitimate-appearing gambling proceeds, bypassing AML checks.
- Weak oversight or inconsistent compliance at local betting shops further reduces the likelihood of suspicious transaction detection.
- Criminals collude at casino tables or online gambling platforms to deliberately lose chips to a prearranged recipient, disguising illicit fund transfers as normal gameplay.
- The recipient then cashes out these funds as purported 'winnings,' lending the appearance of legitimate gambling proceeds.
- By repeating or structuring losses over time and across multiple sessions, launderers obscure the source of funds and complicate AML detection efforts.
- Junket promoters arrange VIP casino access and private credit lines that bypass standard AML checks, obscuring the true ownership of funds.
- Off-book debt settlements and payouts disguised as legitimate gambling winnings make it difficult to trace the origin of illicit proceeds.
- Cross-border junket operations facilitate layering by cycling large sums through casinos in multiple jurisdictions, concealing transaction trails behind perceived gaming activity.
- Criminals bribe or coerce participants to fix sports events, then place bets funded by illicit proceeds.
- Once the rigged event concludes, they collect the ‘winning’ payouts—appearing as legitimate gambling revenues—to disguise the original, illegal source of funds.
- Criminals purchase casino chips with illicit cash or credits, immediately obscuring the true source of funds.
- They engage in minimal or staged gambling, allowing them to redeem chips or TITO tickets as if they are legitimate winnings.
- Some schemes involve buying winning tickets from other patrons at a premium, thus documenting false gains rather than disclosing criminal proceeds.
- Forged tickets or receipts may also be presented to substantiate fabricated gambling earnings, further concealing illicit origins.
- Criminals mirror legitimate betting frameworks by purchasing winning tickets from genuine bettors, masking the origins of illicit cash as legitimate gambling winnings.
- They forge or obtain receipts from licensed gambling operations and present them as genuine payouts, enabling large sums of illicit money to appear lawfully earned.
- Adversaries target remote gambling platforms with insufficient or lax ID checks, registering multiple accounts using misleading or stolen credentials.
- Repeated or slightly altered document submissions allow them to evade detection while funneling illicit funds through bets or withdrawals.
- Such remote KYC gaps provide minimal scrutiny, allowing criminals to maintain unverified accounts undetected.