Criminals convert illicit funds into casino chips or credits, engage in minimal or staged gambling play, and then redeem the balances to appear as legitimate winnings. They often exploit these chip-based transactions to obscure the original source of funds, for instance by feeding smaller banknotes into slot machines and requesting higher-denomination payouts or vouchers (commonly called TITO tickets), thereby eluding scrutiny. Some schemes involve forged receipts or buying winning tickets from legitimate gamblers at a premium, enabling launderers to document false gains instead of disclosing the true criminal origin. In other instances, proceeds (e.g., from drug trafficking) are directly exchanged for chips and later cashed out as purported gambling profits, even though actual wagering may be minimal. These techniques allow criminals to transform illicit cash into apparently lawful proceeds under the guise of normal casino activity.
Casino Chip Conversions
Casino-Based Approaches
Tactics
Criminals exchange illicit cash for casino chips or credits, thereby introducing those criminal proceeds into the financial environment under the guise of legitimate gambling returns. This initial conversion of illegal funds reduces the immediate detection risk by masking them as part of normal casino transactions.
Risks
Criminals exploit the inherent features of casino chips and TITO tickets, which allow easy conversion from physical cash into gambling credits and back again with minimal scrutiny. By engaging in minimal or staged wagering, they can redeem chips or vouchers as purported winnings, effectively masking the illicit source of the funds. This vulnerability is tied to the product’s design, wherein large cash buy-ins and quick redemptions are not always flagged, enabling criminals to pass off illicit proceeds as legitimate gaming returns.
Indicators
Multiple individuals funnel chips or stored-value balances to one person, or vice versa, indicating consolidation or dispersal outside typical group gambling activity.
Rapid chip cash-outs with minimal wagering activity, structured to artificially appear as legitimate gambling returns.
Recurring chip transfers among multiple customers with no clear legitimate gambling rationale.
Intentional or staged chip losses from one gambler to another followed by immediate cash redemption, suggesting contrived transfers rather than genuine gambling outcomes.
Consecutive chip purchases and near-immediate cash redemptions with limited intervening play, disguising the original source of funds under purported winnings.
Large cash buy-ins for gaming chips that exceed typical spending levels or deviate significantly from a customer's known gambling profile.
Frequent redemption of TITO vouchers acquired from other patrons or in ways inconsistent with the redeemer’s observed gambling activity.
Attempts to redeem forged or altered winning tickets or receipts that do not match the casino’s internal gaming logs.
Data Sources
- Provides granular details of chip purchases, redemptions, TITO vouchers, and patron identities.
- Logs each wager and payout event, enabling analysis of minimal gambling, large or frequent buy-ins, and rapid cash-outs.
- Includes ticket serial numbers, issuance timestamps, and machine reconciliation records, supporting detection of forged receipts or inconsistencies between winnings claimed and actual gaming activity.
- Helps identify unusual chip transfers among patrons and patterns of staged losses or transfers immediately preceding redemptions.
Mitigations
Collect and verify detailed customer identification whenever individuals buy or redeem chips beyond established thresholds. Require clarity on the source of funds for large or repeated transactions to mitigate the risk of anonymous high-value play that conceals illicit proceeds behind purported gambling funds.
Configure automated alerts and real-time surveillance to detect unusual chip conversions, such as rapid buy-ins with minimal betting or frequent TITO redemptions among patrons lacking legitimate gambling activity. Flag patterns where multiple small buy-ins aggregate into larger payouts, indicating possible cash structuring under the guise of gambling wins.
Enforce threshold-based reporting for substantial cash chip purchases or redemptions. Cross-check repetitive cash-ins near reporting limits to identify potential structuring attempts, ensuring that casino-based cash movements above set thresholds are documented and reported to authorities as required.
Train cage, floor, and VIP personnel to identify minimal or staged gambling activities, such as large chip redemptions and TITO voucher exchanges from unrelated individuals. Be vigilant for suspicious activities like forged or purchased winning tickets. Ensure staff are aware of specific red flags, such as quick buy-ins followed by immediate cash-outs and multiple patrons funneling chips to one person. Establish clear internal escalation protocols to facilitate prompt investigation and reporting.
File timely SARs/STRs whenever staff observe repeated high-value chip purchases or redemptions with minimal play, attempts to cash forged TITO tickets, or bulk chip passing among multiple patrons without legitimate gaming rationale. Detailed reporting helps authorities investigate potential chip-based laundering schemes.
Instruments
- Criminals exchange illicit cash for casino chips, converting physical funds into a recognized casino asset.
- They conduct minimal or staged betting, then redeem the chips for purported 'winnings,' masking the original source of funds.
- Opaque chip transactions help criminals disguise illicit proceeds as legitimate gambling payouts.
- Criminals insert small-denomination bills into slot machines, generating larger payout vouchers (TITO tickets) with little or no actual gameplay.
- They redeem these tickets for higher-denomination payouts, falsely presenting illicit funds as genuine casino winnings.
- In some cases, launderers purchase or forge winning TITO tickets from others, further obscuring the true origin of the funds.
- Criminals bring illicit physical banknotes into the casino, purchasing chips or loading slot machines under the guise of normal gambling activity.
- By breaking purchases into smaller denominations or transactions, they can avoid triggering certain AML thresholds or ID checks.
- This enables the initial placement of illicit proceeds, obscuring their origin within standard casino operations.
Service & Products
- 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.
Actors
Drug traffickers introduce proceeds from narcotics sales into casinos by purchasing chips or loading slot machines with illicit cash.
- They engage in minimal wagering, then convert the chips or TITO tickets back into higher-denomination payouts.
- This process masks the original source of the money when financial institutions later receive or process what appear to be gambling profits.
Legitimate gamblers become involved when criminals buy their winning tickets or vouchers at a premium, transferring the appearance of legal winnings to the launderer.
- By claiming these tickets as their own, launderers transform illicit funds into documented gaming profits.
- Financial institutions have difficulty distinguishing these funds from genuine gambling proceeds during subsequent deposits or transfers.
References
APG (Asia/Pacific Group on Money Laundering). (2018, July). APG Yearly Typologies Report 2018. APG Secretariat. https://apgml.org/documents/default.aspx
AUSTRAC (Australian Transaction Reports and Analysis Centre). (2007). AUSTRAC Typologies and Case Studies Report 2007. Commonwealth of Australia. https://www.austrac.gov.au/sites/default/files/2019-07/typologies_report_2007.pdf
GAMLG (Gambling Anti-Money Laundering Group). (2017). GAMLG's AML risk assessment for licensed betting offices (LBOs) and remote gambling industries. GAMLG. https://bettingandgamingcouncil.com/uploads/Downloads/GAMLG-Risk-Assessment.pdf
Akartuna E.A., Johnson S.D., Thorton A.(2024). Motivating a standardised approach to financial intelligence: A typological scoping review of money laundering methods and trends. Journal of Experimental Criminology. https://link.springer.com/article/10.1007/s11292-024-09623-y