Key points include:
➡️ New typologies identified: FATF highlights criminals using gambling platforms to move money without actually gambling, "smurfing" through multiple small transactions to avoid detection, and unusually large or co-ordinated bets on events flagged for possible competition manipulation;
➡️ Illegal gambling as a major risk: In many jurisdictions illegal gambling markets rival or exceed the size of legal markets, with unlicensed offshore operators often presenting themselves as legitimate businesses while offering anonymity to attract criminal actors;
➡️ Beneficial ownership and criminal infiltration: Platform shareholding can be structured to bypass thresholds for regulatory checks, particularly where AML/CFT controls and anti-corruption frameworks are weak, compounding long-standing risks of organised crime groups seeking ownership or influence over operators;
➡️ Financial system access points: Payment systems used in gaming and gambling, including cash, e-wallets, mobile money and virtual assets, are vulnerable to money laundering risks, with red flags including multiple accounts and payment methods under different identities and discrepancies between customer and payment information; and
➡️ Links to wider offending: The project identified connections between gaming and gambling abuse and corruption, cyber-enabled fraud, professional money laundering networks and illegal or unlicensed offshore operators.
✅ Firms operating in or servicing the gaming and gambling sector should incorporate FATF's new risk indicators into their financial crime risk assessments and transaction monitoring rules, and strengthen beneficial ownership (BO) due diligence to identify structuring designed to evade regulatory thresholds.