Electronic Gaming Machine Ticket Redemption

Criminals insert illicit cash into electronic gaming machines (e.g., slots or pokies), converting it into TITO (ticket-in, ticket-out) vouchers or credits with either minimal or no actual gambling, which disguises the origin of funds. By splitting their deposits across multiple visits, exploiting high payout or low-risk machines, and rapidly cashing out tickets, launderers mask suspicious lump sums as normal gaming activity. These TITO vouchers can also be exchanged among accomplices or consolidated into larger payouts later, further complicating traceability. Once redeemed, these funds are deposited or exchanged through financial institutions, falsely appearing as legitimate gambling winnings and completing a layer of criminal fund integration.

[
Code
T0054
]
[
Name
Electronic Gaming Machine Ticket Redemption
]
[
Version
1.0
]
[
Parent Technique
]
[
Tactics
]
[
Risk
Product Risk
]
[
Created
2025-02-13
]
[
Modified
2025-04-02
]

Pokie

Slot Machine

Video Gaming Terminal

EGM

Tactics

ML.TA0006
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Criminals introduce illicit cash into gaming machines as an initial infiltration of funds, converting physical currency into TITO tickets that appear to be legitimate gambling proceeds. This tactic reduces detection risk by merging illegal cash with normal gaming activities.

Risks

RS0002
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Product Risk
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Criminals exploit the TITO-based gaming product feature that converts large volumes of physical cash into vouchers with minimal recorded betting activity. By repeatedly inserting illicit funds into gaming machines and quickly cashing out TITO tickets, they mask the true origin of the proceeds under the guise of legitimate gambling winnings. This is the primary vulnerability because the product’s structure and limited scrutiny for individual TITO transactions enable swift conversion and redemption of illicit cash, making it appear legitimate.

Indicators

IND00473
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Frequent and immediate conversion of inserted cash to gaming credits and subsequent cash-out with no recorded gambling losses.

IND02736
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Large volumes of cash are inserted into electronic gaming machines with minimal bet activity, departing from typical gaming usage patterns.

IND02737
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Redemption tickets or credits are quickly converted back into cash or checks shortly after minimal betting activity, departing from typical gaming cash-out patterns.

IND02738
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Repeatedly high cash deposits into gaming machines accompanied by consistently low betting activity, diverging from typical player behavior.

IND02739
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Repeated cycles of cash insertion, negligible betting, and rapid cash-out through redeemed gaming credits or tickets indicate a behavioral pattern inconsistent with normal gaming risk exposure.

IND02740
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A pattern of rapid and repetitive gaming transactions, where funds are cycled from cash to electronic credits and back to cash within short time intervals, raising concerns during behavioral reviews.

IND02741
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Multiple redemption tickets in the same day across different machines or in different casino locations.

IND02742
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TITO vouchers are exchanged or transferred among multiple customers without a clear legitimate relationship, followed by consolidated ticket redemptions.

IND02743
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Significant or frequent bank deposits from TITO voucher redemptions inconsistent with the customer’s known gambling habits or financial profile.

Data Sources

Offers comprehensive deposit and transaction histories, ownership details, and account balance information. Cross-referencing TITO voucher redemption proceeds with an account holder’s established financial profile helps identify deposits that are inconsistent with stated gambling habits or declared income.

Provides verified customer identity details, beneficial ownership information, and relationship mappings. This data helps identify whether individuals exchanging or consolidating TITO vouchers are legitimately connected or part of collusive activity, enabling enhanced scrutiny of unusual or unexplained voucher transfers.

Contains detailed records of TITO (ticket-in, ticket-out) issuance and redemption, amounts inserted into electronic gaming machines, timestamps, betting activity, and payout details. This data enables tracking minimal-play or no-play scenarios, rapid cash-outs, and the overall flow of funds through gaming machines, helping detect patterns consistent with illicit layering or integration.

Mitigations

Require verified identification for TITO redemptions or high-value cash transactions above defined thresholds. Perform risk-based assessments on frequent or large TITO redeemers to verify the source of funds and confirm legitimate gambling activity. Enforce maximum redemption limits without verified identity to prevent structuring through multiple sub-threshold transactions.

Integrated surveillance connects machine-level transactions with an individual's profile. Use behavioral analytics on machine data to detect short-play patterns or rapid insert/cash-out cycles.

  • Submit CTRs for TITO-related cash deposits or redemptions that exceed mandatory thresholds to create an official record of large or structured casino transactions.
  • This documentation supports investigations into repeated sub-threshold structuring or unusually high-volume TITO usage.

Maintain comprehensive logs of all TITO transactions, recording amounts, machine IDs, timestamps, and linked player or ID details. Share these logs across relevant venues or partner entities (where legally permissible) to identify repeated or structured cash insertions and redemptions used to disguise illicit funds.

Blacklist or bar individuals identified for TITO-based laundering attempts from using electronic gaming machines or entering gambling venues. Apply cross-venue bans to prevent repeated exploitation of rapid cash insertion and ticket redemption, thereby disrupting known offenders' access to TITO transactions.

Instruments

IN0004
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  • Casinos may issue checks for larger TITO redemptions, offering a credible bank-drawn instrument.
  • Criminals deposit these checks into their accounts, where they appear legitimate due to the casino’s reputable status.
  • The check form factor further distances the funds from their original cash source, complicating financial institution scrutiny.
  • Once TITO vouchers are redeemed for cash or checks, criminals deposit the proceeds into bank accounts as purported gambling winnings.
  • Financial institutions typically regard verified casino payouts as legitimate, enabling launderers to integrate illicit funds with minimal suspicion.
  • These deposits complete a layering step by transforming illicit cash into apparently legitimate account balances.
IN0034
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  • After minimal or no actual betting, criminals convert inserted cash into TITO tickets, making it appear as legitimate winnings.
  • These tickets are transferable among accomplices or consolidated to mask the true source of funds, scattering or regrouping the original amounts.
  • Once redeemed, the proceeds appear to financial institutions as ordinary casino payouts, further obscuring their illicit origin.
IN0051
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  • Criminals insert illicit banknotes directly into electronic gaming machines, immediately converting them into TITO credits or vouchers.
  • The anonymity of physical bills obscures the money’s illicit origin, especially when deposits are split below thresholds or across multiple sessions.
  • This tactic effectively places dirty cash into the financial system by giving it the appearance of legitimate gambling proceeds at the earliest stage.

Service & Products

  • 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.

Actors

Illicit operators insert substantial cash into TITO gaming terminals with little to no betting activity, splitting deposits across multiple sessions or machines. They exchange or consolidate vouchers to further distance the funds from their illicit origin, complicating transactional traceability for financial institutions.

Financial institutions receive TITO redemption proceeds as purported gambling winnings. These deposits hinder detection efforts because the original source of funds—large volumes of illicit cash—remains obscured by the casino-based conversion process.

References

  1. FATF (Financial Action Task Force). (2009, March). Vulnerabilities of Casinos and Gaming Sector. FATF. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Vulnerabilitiesofcasinosandgamingsector.html

  2. Gambling Commission, United Kingdom. (2017, November). Money laundering and terrorist financing risk within the British gambling industry. Gambling Commission. https://www.gamblingcommission.gov.uk/