Principal threats related to money laundering in the United States:3. Fraud. Drug Trafficking. Human smuggling. Human trafficking. Corruption. Transnational Criminal Organizations Moreover, as stressed in the U.S. Treasury’s 2015 National Money Laundering Risk Assessment, “most often criminals who use casinos to launder. National Money Laundering Risk Assessment –; Money Laundering through the Football Sector-; Best Practices Paper On Special Recommendation III-; Vulnerabilities of Casinos and Gaming Sector-; Risk-Based Approach – Guidance for Casinos-; Risk-Based Approach – Guidance for Legal. The sale of high value notes, in any currency, entails a significant money laundering risk. All major UK banks and financial institutions agreed not to sell €500 notes. The customer is willing. But money laundering is still big business, here and abroad. The 2016 Basel AML Index, which ranks countries for their money laundering risk, put Iran at No. 1, at greatest risk among 149 countries. Finland came in last—or best—with the least risk. Ranked 97th, leaving room for improvement. China came in 39th and the United Kingdom. In October 2008, the FATF adopted Guidance on the Risk-Based Approach (RBA) to combating Money Laundering and Terrorist Financing for casinos. This Guidance was developed by the FATF in close consultation with representatives from the casinos sector. This guidance supports development of a common understanding of what the RBA involves, outlines.

Lithuania’s land-based casino industry faces a “very high” risk from money laundering, while the remote gambling sector faces a high risk, according to a risk assessment carried out by the country’s government.

Risk levels for each aspect of Lithuania’s gambling industry were determined through “data from a variety of international and national sources”, international studies and reports and statistics provided by a sample of gambling businesses. The country’s Financial Intelligence Unit, supported by supervisory and law enforcement authorities, also contributed to the study.

According to the report, the risk of money laundering for casinos, defined as the “attractiveness and ability of criminals to exploit a specific medium to launder criminally obtained property” was rated as the maximum 4 on the report’s 1-4 scale.

“The casino sector is exposed to risk because the activity is based on a significant number of cash flows, which is attractive for organized crime groups, PEPs [politically exposed persons] and those coming from high-risk countries to launder money,” the report explained. “The Modus operandi is easy to implement as it requires basic planning and basic knowledge of how gambling systems work.”

The risk level for slot machine parlours, betting and online gambling were all rated as a 3, indicating a high risk.

“The online gambling industry is attractive for ML due to the high volume and fast execution of transactions (including cross-border transactions) as well as low identification requirements, which allows criminals to easily convert illegal funds into legitimate gambling earnings,” the report concluded.

For lotteries, the risk was rated as 2, indicating a medium risk.

The report also rated the vulnerability of each medium to money laundering, based on the “totality and effectiveness of measures aimed at preventing the realization of a money laundering risk, taking into account the scale and perception of the risk”. Once again this used a 1-4 scale, with a 4 indicating the most vulnerable.

For land-based casinos, betting and slot parlours, this was rated as a 3 for high vulnerability.

“Casinos allow only cash operations and do not verify the source of funds,” the government said said. “In addition, the sector has difficulties in performing customer due diligence (there is no evidence that all casinos would employ systems to identify related transactions of players), sanction checks and PEP identification.

“Also, some casinos have customers from sanctioned or high-risk countries, such as Iran and Syria. However, casinos are the most aware of money laundering risks in comparison with other gambling sectors.”

The report added that the country’s Gambling Supervisory Authority was ill-equipped to deal with the threat of money laundering in casinos.

“The number of investigations carried out by supervisory authorities during 2016-2018 is insufficient and not proportional to the risk of the sector. This might be caused by the lack of human resources of the supervisory authority, which has only three employees dedicating only 15% of their time for [money laundering and terrorist financing] supervision within the sector.”

The report suggested allowing casinos, slot parlours and betting to use debit cards for more easily traced transactions, setting limits on cash deposits, the usage of player cards to track each player’s gambling activity and “secret shopper” style inspections from the Supervisory Authority.

Remote gambling and lotteries were both rated a 2 for medium vulnerability, though the report noted that some online operators have stricter anti-money laundering requirements than others.

The report marked the second time Lithuania had completed a National Money Laundering and Terrorist Financing Risk Assessment, with a previous iteration in 2015.

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NZ-to-Pacific Money Remittance sub-sector Risk Assessment (July 2021)
Identity Verification Code of Practice (updated July 2021)
Annual Reports (updated June 2021)
Territorial Scope of the AML/CFT Act 2009 (updated November 2019)
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Financial Institutions Factsheet

Any financial institution, either existing or established after the introduction of the AML/CFT Act came into force on June 2013, that in the ordinary course of business carries on one or more of the financial activities captured by the Act, is a reporting entity and must comply with the legislation and regulations.

This factsheet outlines what financial institutions are required to do to meet their AML/CFT obligations.

Financial Institutions Factsheet (PDF, 778KB)

Developing your Risk Assessment and Programme

AML/CFT Programme Guideline

The guideline is designed to help reporting entities develop their AML/CFT programme as required under section 56 of the AML/CFT Act.

AML/CFT Programme Guideline (PDF, 171KB)*
AML/CFT Programme Guideline (Word, 1.3MB)

Developing an AML/CFT programme is the next step after conducting a risk assessment. It involves developing the procedures, policies and controls to manage and mitigate money laundering and terrorism financing risks. A reporting entities AML/CFT programme must be based on their risk assessment.

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The AML/CFT Risk Assessment Guideline is designed to help reporting entities conduct a risk assessment, as required under section 58 of the AML/CFT Act.

Risk Assessment Guideline (PDF, 155KB)*
Risk Assessment Guideline (Word, 1.3MB)

A risk assessment is the first step a business must take before developing an AML/CFT programme. It involves identifying and assessing the risks the reporting entity reasonably expects to face from money laundering and terrorism financing. Once a risk assessment is completed, a reporting entity must then put in place an AML/CFT programme that manages and mitigates these risks.

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This guideline provides reporting entities with a series of questions, supervisory expectation, reference material and suggested best practice that will help guide their risk assessment and programme. It provides a starting point, which can be supplemented with more detailed information provided by DIA supervisors. This guideline can be used by all DIA-supervised reporting entities, both small and large.

This guideline is not mandatory. Reporting entities may choose to use alternative methodologies to conduct their risk assessment and develop their programme.

AML/CFT Risk Assessment and Programme: Prompts and Notes for DIA reporting entities (PDF, 1MB)

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The Financial Institutions Sector Risk Assessment (SRA) is a review of the characteristics of the sectors covered by the AML/CFT Act including remitters, virtual asset service providers, payment providers, lenders and other financial institutions. This document is intended to help AML/CFT supervisors understand the mone

The Greatest Risk For Money Laundering Is For Casinos That