Gambling operators in 2025 must take into account the international FATF (Financial Action Task Force) standards governing the criteria linked to money laundering (ML) and terrorist financing (TF). Below is a full overview of the FATF recommendations for the gambling sector, updated and translated into English without shortening the content.
What Is FATF?
FATF — the Financial Action Task Force — is an intergovernmental body responsible for combating money laundering and terrorist financing. FATF establishes and regularly updates international standards aimed at preventing financial crime and the societal harm associated with it.
More than 200 countries and jurisdictions have committed to implementing FATF standards. Governments rely on these recommendations to trace criminal proceeds generated from illegal drug trafficking, human trafficking, organized crime, fraud, tax evasion, corruption, and other offences.
FATF continuously monitors emerging ML/TF threats across sectors and updates its standards accordingly. The gambling industry is not an exception: based on extensive research, FATF developed specific recommendations for casino operators and regulatory authorities responsible for AML/CFT supervision in the gambling sector.
Vulnerability Factors in the Gambling Sector
FATF identifies a range of vulnerability factors that influence the risk level of money laundering or terrorist financing in casinos and the broader gambling industry. These include:
- the legal and regulatory framework of the jurisdiction
- economic characteristics of both the gambling sector and the broader national economy
- ownership structure, integrity, internal controls, and corporate governance of casinos
- ownership transparency and integrity of intermediaries and associated businesses (junket promoters, agents, gaming equipment providers, financial service providers)
- types of services offered by the gambling business
- domestic and foreign criminal activity, including profits laundered through the local market
- financial services provided within the gambling sector (junket tours, promoters, agents, high-value transactions, etc.)
A comprehensive investigation by the Royal Canadian Mounted Police (RCMP) once highlighted similar observations. Their study included typology analysis, interviews with casino staff (including senior management), and cross-referencing with intelligence databases. They concluded that ML risks depend on many factors: the size of the casino market, number and type of facilities, location, ownership structure, and the degree to which casinos function as financial intermediaries. In some recorded cases, casinos were involved in crimes resembling ML — such as credit fraud or cheque fraud.
Casinos Are Not Banks — But Sometimes They Function Like Financial Institutions
Although casinos are technically considered non-financial institutions, many of their daily operations closely resemble those of banks. Casinos often offer services such as:
- accepting deposits
- cash exchange
- wire transfers
- foreign currency exchange
- storage of valuables
- cashing checks
- issuance of casino checks
- credit services
Most of these services operate around the clock, allowing criminals to exploit the high transaction volume and speed.
Because of this, casinos are attractive ML targets. Criminal groups may try to influence or infiltrate the financial operations of the casino or collaborate with its owners. In such scenarios, AML monitoring becomes the only effective safeguard against illicit activity.
How Criminals Launder Money Through Casinos
FATF and national law enforcement agencies have identified multiple methods used by criminals to launder money in gambling establishments, including:
- using casino instruments (cash, chips, slot machine credits, markers, casino checks, gift cards, vouchers, loyalty cards)
- structuring (breaking down large amounts into small transactions)
- using casino accounts
- intentional losses at gaming tables
- combining legitimate winnings with illegal cash
- foreign currency transactions
- using casino employees as accomplices
- credit/debit card manipulation
- forged or fraudulent identification documents
A central role is often played by casino chips, which exist in three types:
- standard chips,
- credit chips (issued to players on credit),
- “dead chips” (non-cashable chips given to junket participants).
One of the most common ML schemes involves purchasing chips with illicit cash and later redeeming the same amount through a casino-issued check or wire transfer. A more sophisticated version involves converting chips into credit and transferring that credit to another jurisdiction where the casino has a branch, allowing funds to exit as “clean” casino checks.
FATF also notes cases in which criminals purchase “clean-history” chips at a premium from other players — essentially buying legitimacy.
In some jurisdictions, casino checks can be cashed outside the casino and used as payment for goods, assets, or reinvestment into criminal enterprises.
Another ML typology involves blending illegal cash with legitimate winnings so that the entire amount appears clean on a casino check.
Chips may also function as currency for illicit transactions (weapons, drugs, smuggling). Storing assets in chips allows criminals to justify possession of large sums and convert them to cash discreetly later.
Gift cards from casinos can also be used to legitimize illegal funds — criminals purchase them and pass them on to others to redeem legally.
All FATF recommendations are based on real-worldケース from international gambling markets.
Real Money Laundering Cases Involving Casinos
Australia
Criminals used casinos to launder millions by:
- converting chips into cash without gambling
- playing slot machines to cycle funds and present them as winnings
- using low-return but high-win-probability games to simulate legitimate play
Another investigation found that a drug trafficker conducted around 50 betting-related transactions, mostly chip-to-cash conversions, totaling AUD 890,000 while showing minimal actual gambling activity.
Belgium
Two individuals entered a casino and purchased €25,000 worth of chips. They did not gamble; instead, they immediately cashed out the amount through a third party. Investigators discovered all three were students suspected of human trafficking. Their goal was to create a plausible source of income using casino payout records.
United Kingdom
Two criminals were arrested for cheque fraud totaling £25,000. They robbed a victim and found two Barclays Bank cheques in the victim’s belongings, which they used to buy chips in a London casino. The casino was cleared of wrongdoing.
United States
One notable case involved casino loyalty cards. A criminal purchased these cards using illegal funds from regular customers. As players accumulated points, the criminal exchanged them for gold coins at the casino store, with the help of a corrupt employee.
Another high-profile case involved a New Jersey attorney convicted of stealing $500,000, laundering $250,000 through an Atlantic City casino. He deposited $250,000 into a casino account, bought chips, gambled for one hour (losing around $10,000), cashed out $240,000, and left.
How Casino Employees Can Detect Money Laundering
FATF highlights key red flags casino staff should monitor. AML officers, regulators, and managers should watch for:
- depositing money into a slot machine and immediately requesting it as a credit
- requesting payouts or credit without a real jackpot
- demanding unusually large payouts from slot wins
- sudden changes in spending or betting patterns
- depositing large sums into high RTP machines while betting minimum amounts to avoid losses
- placing offsetting bets (e.g., roulette, baccarat, craps) that cancel each other
- no real interest in gambling or winning
- multiple players betting against each other in peer-to-peer games
- attempts to befriend casino staff
- players carrying large quantities of coins or currency
- purchasing and cashing chips with almost no gambling activity
- a high volume of transactions in a short period
- multiple chip cash-outs in a single day
- cash-out amounts equal or nearly equal to chip purchases
- requests for credit transfers to foreign casinos
- use of third parties or multiple credit cards to purchase chips
- buying chips and leaving the casino immediately
- frequent purchase of casino gift certificates
- players bringing in chips from unknown sources
- difficulties verifying a customer’s identity (fake documents, being banned from other casinos)
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