Chip Dumping

Chip dumping is a collusive gambling practice where one or more players deliberately lose chips to a designated recipient, effectively transferring illicit funds under the guise of normal betting. By coordinating through physical table games (such as poker, blackjack, or roulette) or online platforms, criminals obscure the true ownership of the money, which eventually appears as legitimate winnings upon cash-out. They may structure these transfers gradually through multiple small bets over a longer period or execute high-value losses right after buy-in, complicating detection. In online settings, chip dumping commonly relies on minimal KYC measures, and launderers may even combine it with stolen credit cards—depositing funds into one account, then systematically losing to another conspirator’s account. Criminals can further mask activity by using multiple accounts, e-wallets, or mobile payment methods to make rapid chip transfers and quickly withdraw the laundered winnings. Jurisdictions with weaker oversight and easily accessible online gambling sites are particularly vulnerable, allowing organizers to replicate this technique at scale across numerous platforms.

[
Code
T0107.003
]
[
Name
Chip Dumping
]
[
Version
1.0
]
[
Tactics
]
[
Risk
Product Risk, Jurisdictional Risk
]
[
Created
2025-02-27
]
[
Modified
2025-04-02
]

Chip Passing

Chip Transfer

Tactics

ML.TA0007
|
|

Chip dumping involves scattering or consolidating illicit funds across multiple players, using collusive betting to obscure the origin and ownership of proceeds. By making the transfers appear as legitimate gambling losses and winnings, criminals create complex transaction patterns that frustrate investigative tracking.

Risks

RS0002
|
Product Risk
|

Chip dumping exploits the vulnerability of gambling products, where chips (physical or virtual) can be transferred among players with insufficient oversight. Criminals collude to lose chips to a designated account, thereby masking illicit fund transfers as legitimate 'gaming' wins. This intrinsic feature of gambling products—facilitating chip exchange or wagers between players—provides the primary avenue for laundering.

RS0004
|
Jurisdictional Risk
|

Criminals target or operate within jurisdictions with lax gambling regulations and minimal AML enforcement, enabling large-scale collusive wagering with little to no meaningful oversight. By selecting regions or online gambling sites with weaker licensing standards, they repeatedly replicate chip dumping schemes across multiple platforms.

Indicators

IND00601
|

Repeated large chip losses from one player to another within a short timeframe.

IND00602
|

A player consistently losing large amounts of chips to the same opponent or group of opponents across multiple sessions.

IND02213
|

Sudden increase in the volume of chips being transferred between players, especially when not aligned with game events.

IND02243
|

Multiple accounts consistently losing to a single account, indicating coordinated activity.

IND02244
|

A typically high-ranked or experienced player consistently losing to a novice or newly registered player, contrary to normal skill expectations.

IND02245
|

Frequent or rapid chip transfers between accounts not justified by normal gameplay events or outcomes.

IND02246
|

Newly created accounts or those with no prior gameplay history that engage in high-value chip transactions soon after registration.

IND02247
|

Gameplay patterns indicating the losing player is deliberately not attempting to win or using a strategy inconsistent with typical play.

IND02248
|

Players engaged in suspicious chip transfers share contact details, IP addresses, or other account attributes indicating collusion beyond normal gameplay.

IND02249
|

Multiple accounts frequently interacting with each other, with one account consistently losing to the others.

IND02250
|

High-stakes bets leading to large losses to a specific player, inconsistent with ordinary betting behavior.

IND02251
|

Players who log in from the same IP address or device while purporting to be separate user accounts.

IND02252
|

Accounts that show a pattern of depositing funds, losing chips through gameplay, and then withdrawing funds.

IND02253
|

Players who frequently switch tables or games immediately after substantial chip losses.

IND02254
|

Deposits from payment cards or methods flagged as fraudulent, followed by rapid losses to other accounts and subsequent withdrawals.

Data Sources

  • Captures transaction details, user identifiers, e-wallet usage, mobile payment methods, and related operational data from digital platforms.
  • Identifies suspicious deposit or withdrawal patterns, frequency, and velocity across multiple accounts.
  • Correlates with casino transaction records to detect rapid chip transfers and potential collusion or funneling of funds in chip dumping schemes.
  • Contains IP addresses, device fingerprints, login timestamps, and other network metadata.
  • Identifies cases where multiple purportedly separate player accounts share common access points, indicating potential collusion.
  • Assists in uncovering suspicious account overlaps, rapid logins from the same device, and other anomalies consistent with chip dumping schemes.
DS0033
|
|
  • Contains records of known fraudulent payment methods or compromised payment cards.
  • Enables detection of deposits originating from stolen cards or flagged payment sources used to fund chip dumping accounts.
  • Supports investigations by correlating fraudulent payment activity with rapid or unusual chip losses to conspirator accounts.
  • Includes verified customer identity documents, account creation timelines, and beneficial ownership information.
  • Helps detect newly registered or minimally vetted accounts quickly engaging in high-value chip transactions.
  • Provides a means to identify multiple suspicious accounts linked to the same individual or incomplete KYC profiles, a common tactic in chip dumping.
  • Provides comprehensive logs of gambling transactions and gameplay, including buy-ins, bet sizes, transaction timestamps, game outcomes, and associated player identifiers.
  • Enables direct detection of suspicious transfers of chips through unusual patterns of wins and losses, repeated large losses from the same accounts, and collusive gameplay indicative of chip dumping.
  • Facilitates investigations by correlating deposit or withdrawal data with anomalous bet amounts and rapid chip movements.

Mitigations

Require robust identification and verification for all gambling accounts, ensuring that each user provides valid documentation and verified payment sources. This deters launderers from exploiting minimal KYC to open multiple fraudulent accounts or deposit and dump chips through stolen credit cards.

Implement dedicated chip-transfer analytics and automated alerts within the gambling platform to identify repeated large chip losses or highly irregular betting patterns indicative of collusion, such as systematic losses to the same opponent or abrupt high-value losses immediately after a buy-in. Promptly investigate or freeze suspicious transfers to stop ongoing chip dumping.

Enforce strong user authentication, such as multi-factor authentication, and track device/IP usage to identify multiple accounts operated by the same person. By correlating login patterns, institutions can identify collusive rings that leverage shared or overlapping access points to facilitate chip dumping.

Train casino or online gambling staff to detect hallmark chip dumping signals, such as large, consistent losses by experienced players to new, underperforming accounts or abrupt betting shifts after a deposit. Ensure these red flags are promptly escalated to compliance teams for further action.

Restrict high-stakes betting or freeze accounts if suspicious chip transfers emerge, such as repeated large losses to a single beneficiary, until thorough investigations are completed. For newly opened or unverified player accounts, impose tighter bet limits or require additional verification when abrupt, high-value chip losses occur.

Instruments

IN0001
|
|
  • In physical casinos, illicit funds are exchanged for chips and then purposely lost to an accomplice at the table.
  • The accomplice redeems the chips as legitimate gambling proceeds, obscuring the illicit source.
  • Repeated or structured chip losses complicate investigations, making each transaction appear as ordinary gameplay rather than orchestrated collusion.
  • Criminals deposit illicit funds into one or more online gambling accounts with minimal KYC requirements.
  • They deliberately lose chips to a co-conspirator’s account, effectively transferring the illegal funds.
  • The co-conspirator then withdraws or “cashes out” these chips as gambling winnings, falsely legitimizing their origin.
  • Multiple or newly created accounts can be used to repeatedly structure, conceal, and fragment these transfers.
  • Criminals fund gambling balances using stolen or fraudulent cards.
  • They execute carefully orchestrated losses, transferring illicitly obtained card funds to another conspirator’s account.
  • The conspirator then withdraws these diverted funds as apparent gambling winnings, effectively laundering the original card transactions.
IN0051
|
|
  • Criminals purchase casino chips using bulk cash and coordinate deliberate chip losses to a co-conspirator.
  • The physical nature of cash, combined with multiple small purchases or rapid buy-ins, obscures the original source of the illicit money.
  • Once cashed out, the funds appear as standard gambling winnings with reduced traceability due to the anonymity of banknotes.
  • Launderers use prepaid cards or e-wallets to rapidly move funds into gambling platforms.
  • By losing chips to a co-conspirator and cashing out, they obscure the initially loaded amounts.
  • Minimal KYC requirements and quick transfers between multiple stored-value instruments further complicate tracing the illicit funds.

Service & Products

  • Launderers use stolen or fraudulent credit cards to fund gambling accounts, systematically losing chips to conspirators’ accounts.
  • The conspirators later withdraw the improvised 'winnings' under the guise of legitimate gameplay proceeds, effectively laundering the illicit card-funded amounts.
  • Criminals exploit mobile apps that allow swift transfers of funds to gambling platforms or between co-conspirators, supporting collusive chip dumping.
  • Frequent, small-value transactions via mobile payment methods can evade scrutiny, while high-volume transfers may be obscured by the platform’s rapid transaction environment.
  • 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.
  • Launderers maintain multiple e-wallets to deposit and withdraw funds into gambling platforms where chip dumping occurs.
  • Rapid movement of funds between different wallets and accounts makes tracing and freezing fraudulent transactions more difficult.
  • Minimal KYC requirements on certain digital wallet providers can further conceal true identities.
  • These services facilitate rapid deposits and withdrawals tied to gambling activity, providing launderers with a convenient channel for moving illicit proceeds into and out of gambling platforms.
  • By colluding within the gambling environment, launderers structure chip losses and quickly funnel out the 'winnings' via these payment processors, further obscuring the money trail.

Actors

Organized crime groups orchestrate chip dumping schemes by:

  • Recruiting or directing collusive players to conduct deliberate chip losses or wins across various casino tables or online platforms.
  • Taking advantage of minimal KYC or weaker oversight in certain jurisdictions, enabling multiple accounts or fictitious identities to move funds covertly.
  • Flooding financial institutions with seemingly legitimate gambling proceeds, complicating AML checks and source-of-funds verifications.
AT0038
|
|

Gamblers participate in chip dumping by:

  • Knowingly colluding with other players to deliberately lose or transfer chips, thereby masking illicit funds as normal gaming activity.
  • Using accounts funded by stolen cards or rapid e-wallet deposits, then withdrawing 'winnings' as legitimate proceeds.
  • Structuring repeated chip transactions in small increments to avoid triggering suspicious transaction alerts at financial institutions.

References

  1. GIABA (Inter-Governmental Action Group Against Money Laundering in West Africa). (2021). Money laundering risks of casinos and the gambling sector in West Africa. GIABA Assessment Report. GIABA. http://www.giaba.org

  2. FINTRAC (Financial Transactions and Reports Analysis Centre of Canada). (2024). Special Bulletin on laundering the proceeds of crime through online gambling sites (FINTRAC-2024-SB001). FINTRAC.https://fintrac-canafe.canada.ca/intel/bulletins/gambling-jeu-eng.pdf

  3. Wronka, C. (2021). "Cyber-laundering": the change of money laundering in the digital age. Journal of Money Laundering Control. DOI:10.1108/JMLC-04-2021-0035