Casino & Internet Casino

Recognizing unusual transactions

As a service provider – casino and internet casino – you are familiar with the practices within your line of business. Whether a transaction is considered unusual depends largely on your professional judgment. Your judgment is consistent with what is considered unusual within your profession. In addition to your judgment, there are situations that are unusual by nature and should therefore be reported.

If a situation arises as described in the examples below (not exhaustive), this is a reason to further examine whether the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses. It is not necessary to determine with certainty that the above-mentioned crimes have been committed. You merely need to have an assumption that the transaction can be related to one of these crimes.
If you believe that the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses, you are required to report this under the subjective indicator.

Red flags – Casino and internet casino

• A transaction that is atypical for the client, given the client’s profession or income
• The incoming cash flow consists of many small amounts and the outgoing cash flow of large amounts or vice versa
• The reimbursement to the client takes place via a different account than the one from which the money was deposited
• A cash deposit that is made without the client’s statement using a code name
• Payouts in another currency, in larger denominations, or by check or bank account, while the client has paid in cash for chips or stake

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