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How casinos comply with FATF financial controls
What is FATF and why is it important casino
FATF (Financial Action Task Force) is an intergovernmental group that sets global standards for combating money laundering (AML) and terrorist financing (CTF). Country regulators implement the FATF Recommendations in licensing laws and regulations. For casinos, compliance means the right to work in the market, access to payment rails, protection from fines and reputational risks.
Compliance framework: how a casino "implants" FATF requirements
1. Business Wide Risk Assessment (BWRA): risk map by country, product (slots, live, rates), payment (cards, banks, e-wallets, crypto), channel (web/mobile) and customer segments (VIP, high-rollers).
2. Policies and Procedures: AML/CTF documents with roles and SLAs, forbidden jurisdictions, thresholds and triggers; EDD matrix and document request templates.
3. KYC/CDD for onboarding: identification, confirmation of address, verification of the payment method, verification of RAP/sanctions and adverse media.
4. Risk EDD: Source of Funds/Wealth (SoF/SoW), additional documentation, and limiting for high-risk clients/situations.
5. Continuous monitoring (ongoing due diligence): behavioral and transactional checks after the start of the game.
6. Case-management and reporting: recording of alerts, investigations, escalation, submission of STR/SAR to the authorized body and prohibition of "tipping-off."
7. Record keeping: storage of CUS/transactions/cases for a specified period; Access by role readiness for inspections.
8. Independent control: 3 lines of defense (operations → risk/compliance → internal audit), periodic external audit/review.
9. Staff training: regular trainings with examples of red flags, knowledge testing and attendance log.
10. Vendor-risk and outsourcing: assessment of payment/identification/data providers, contractual KPI/SLA, technical and legal due diligence.
Key FATF recommendations in "translating" to casino processes
Risk-based approach (RBA): the depth of checks depends on the aggregate risk of the customer/product/geo/channel.
Identification and beneficial ownership: coincidence of account name, payment methods and owner of funds; non-admission of third party accounts.
Monitoring and detection of suspicious transactions: speed, fragmentation, transit turnover without game logic, device/IP/payment correlations.
Sanctions and PEP: automatic screening at the entrance and further on a schedule; documenting solutions by coincidence.
Settlements and transfers: rules for international transfers, correspondent relations, Travel Rule for virtual assets (if applicable).
New technologies and crypto: online tracing, wallet risk tags, mixer/bridge policy, VASP whitelists, asset limits.
Retention and data availability: ensure "audit-ready" state - quickly find all documents and logs by client/transaction.
Monitoring practice: what and how to track
Rules: amount thresholds, velocity checks, geo-inconsistencies (document/IP/payment), recurring cards/wallets on different accounts.
ML/scoring: anomaly models by cohort and time; revision and retrain on fresh cases.
Graph analytics: "networks" of related accounts (device ID, IP clusters, payment bundles).
Onchain analysis (with crypto): risk of incoming/outgoing, mixers/darknet/sanctions tags, wallet age.
Alerting and parsing: if triggered - freezing until clarification, request for documents, decision and/or STR/SAR.
Red flags (typical indicators)
Split deposits/leads to bypass thresholds; fast bay-withdrawal with no stakes.
Mismatch between the country of the document, IP and payment infrastructure; frequent device changes/VPNs.
Fresh crypto wallets labeled "mixer/high risk"; chains of transfers without economic sense.
Network of accounts with common cards/wallets/devices; "mules."
VIP volumes in the absence of a confirmed source of funds.
Supplier and partner management (FATF-critical)
Payment providers: licenses, geo-coverage, reporting, sanctions compliance.
CUS/data providers: OCR/biometrics quality, list refresh rate, match accuracy.
Studios/content providers and PSP aggregators: contracts with AML requirements, audit rights, incident reporting.
Outsourcing support/VIP management: role access, AML training, tipping-off ban.
Documentation and storage
KYC package: ID, address (≤90 days), payment confirmations, SoF/SoW for EDD.
Transactions and game logs: amounts, channels, devices, IP, behavioral metrics.
Cases and solutions: alert cause, analysis, customer requests/responses, final action.
Retention periods: within license requirements (usually 5 + years after the relationship/transaction).
Security: Encryption, segmentation, access log, regular backups and recovery tests.
Control organization (3 lines of protection)
1. First line (operations/product/payments): compliance with procedures, correctness of data, primary triages of alerts.
2. Second line (risk/compliance): rules, monitoring, investigations, STR/SAR, training, reporting to the regulator.
3. Third line (internal audit/external evaluation): independent review of the design and effectiveness of the AML/CTF program.
FATF Maturity Metrics
Conversion of alerts into cases and confirmed cases; share of "false noise."
Average investigation time; completeness of case documentation.
POP/sanction screening coverage and rescreen frequency.
Inspection/audit results; elimination of comments on time.
Staff training (tests/certification) and training participation.
Frequent misconceptions
"KYC once - and enough is enough." FATF requires ongoing due diligence and risk review.
"Crypto = Prohibit." It is not a ban that is required, but a manageable framework: online screening, Travel Rule (where applicable), limits, VASP whitelists.
"One vendor will solve everything." You need a combination of sources, plus processes and audit trails.
"If VIP client - checks are weaker." On the contrary: EDD and SoF/SoW are stricter.
Implementation/Reinforcement Plan (Operator Checklist)
1. Update the BWRA and link risk levels to limits and EDD.
2. Rebuild KYC stream: biometrics + liveness, payment verification, third-party ban.
3. Include graph analytics and ML scoring on top of rules; start the model retrain cycle.
4. Set up online analytics and Travel Rule processes if you accept VA/crypto.
5. Strengthen case-management: standard checklists, query templates, who-what-when log.
6. Conduct training for front/payments/VIP teams; run "red-team" simulations.
7. Anchor retention and data security: encryption, role access, recovery tests.
8. Plan an internal audit and external independent performance evaluation.
Mini-FAQ
FATF and the local regulator - which is more important?
In fact - local law and license. But they are usually built according to the FATF Recommendations; inconsistency with them leads to problems with the regulator.
Do I need to tell my customer about STR/SAR?
No, there is a tipping-off prohibition.
Can relatives' cards/wallets be used?
No, it isn't. The FATF approach requires the account holder and account to match, otherwise there is a high risk.
How much to keep documents?
Within the framework of license requirements (usually at least 5 years), including case decision logs.
FATF compliance for online casinos is not one module, but a related system: from risk assessment and strong KYC/EDD to smart monitoring, reporting and auditing. An operator who builds a program in FATF logic gets a sustainable business: secure payments, access to payment partners and minimizing fines - and players get a secure and honest environment for playing.