Monthly Casino Compliance

“The ability to understand, recognize, and report money laundering is greatly increased when associates become familiar with specific actions relative to their department, monetary service(s) or gaming function, and are able to relate those to the goals and intent of money laundering.”

Last month, we introduced you to the money laundering goal methodology (MLGM) to illustrate money laundering goals and the purpose or intent of each goal. The MLGM helps to categorize the broad range of money laundering and present it in the most basic terms, which is key to understanding money laundering overall.

However, with that in mind, knowing a money launderer’s motives is a great first step, but you might still ask yourself: “on the casino floor, what does that really look like?” I mean, if a person wanted to hide their identity during transactions (Conceal) or convert funds to another form (Convert), how would they go about doing that? If someone wanted to create an alibi for their funds (Clean) or store a significant amount of money somewhere outside of the traditional banking system (Store), what specific actions might they take to do that in a casino?

Let’s expand upon what we’ve learned so far and look at specific processes by which money launderers try to achieve their goals. The table below (MLGM Table 2) provides commonly known processes for each money laundering goal.

Goal	Processes
Conceal	Structuring False ID Agent Transactions Chip Walking Seat Switching Uncarded Play Identity Theft
Convert	Small to Large Bills Cash-Out of Debit Card Check Cashing Cash-to-Gaming Instrument
Transfer	Paying Others’ Markers/Expenses Using Chips as a Form of Currency Third-Party Payments
Clean	Acquiring W2-G Forms Commingling/Layering Offset Betting Obtaining Withdrawal Receipts
Spend	Gambling Losses Retail Items Entertainment Food & Beverage
Store	Dormant Front Money Hoarding Chips Casino Check not Deposited Funds Stored on Gaming Wallet

MLGM Table 2 provides key indicators to help further understand money laundering by relating common actions (processes) to specific goals. However, it should be noted: even though all of these are red flags for money laundering, some of these actions could be totally innocent, whereas others are more obvious signs of suspicious intent. For example, just because a guest has uncarded play or is holding on to their chips, does not mean they are money laundering…guests do funny things sometimes. On the other hand, structuring, false ID, identity theft and offset betting are more indicative, as well as suspicious on their own.
One should also note that some processes are not relative to every department, casino product or monetary service. For example, a person cannot chip walk while playing slot machines or cash checks at Table Games. Therefore, associates should familiarize themselves with the specific processes that are applicable to their line of work.
The ability to understand, recognize, and report money laundering is greatly increased when associates become familiar with specific actions (processes) relative to their department, monetary service(s) or gaming function, and are able to relate those to the goals and intent of money laundering.

Applying the Why and How of Money Laundering to Casinos, Paul Camacho, December 15, 2021, LinkedIn, https://www.linkedin.com/pulse/applying-why-how-money-laundering-casinos-paul-camacho

*This article was previously released February 2024.