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How money laundering control (AML) works
What AML is and why it matters
AML (Anti-Money Laundering) is a set of measures that help casinos prevent money laundering and terrorist financing. For the player, this is about the legality and safety of payments; for the operator - about license compliance, work with payment partners and reputation protection. At iGaming, AML is closely related to KYC, transaction monitoring, sanction checks and risk management.
Basic principles of AML in iGaming
1. Risk-Based Approach (RBA): Resources and controls are allocated by customer, product, country and channel risk (web/mobile/crypto).
2. Know your client (KYC/CDD): identification of identity, address, payment methods, if necessary - source of funds (SoF/SoW).
3. Continuous monitoring: monitoring behavior and payments after onboarding, not a one-time check.
4. Recording and reporting: mandatory event logs, data storage and reporting of suspicious transactions.
5. Independence and training: separation of functions (3 lines of defense), regular training of employees, independent audit.
How the AML process is built in online casinos: step by step
1. Risk Assessment (Business-wide Risk Assessment): the operator describes risks by country, product (slots, live, rates), payment rails (cards, bank, e-wallets, crypto), customer segments (VIP, high limits).
2. Policies and procedures: KYC/EDD regulations, limits, triggers, list of prohibited jurisdictions and sanctions lists, escalation procedure.
3. Onboarding (KYC/CDD): ID + address + payment, sanctions/PEP checkers, fingerprint device, geo-IP. For increased risk - EDD: SoF/SoW, additional documentation.
4. Monitoring transactions and behavior: rules/models catch anomalies: speed, fragmentation, circular transfers, sharp jumps in deposits/withdrawals, mismatch with the profile.
5. Triggers and alerts: the system creates compliance cases when thresholds are reached (amount, frequency, pattern).
6. Analysis of cases and solutions: request for documents, time limits, blocking, submission of a suspicious report to the authorized body.
7. Post-control and retention: storage of logs/documents, QA of samples, fine-tuning of rules, personnel training.
Tools and technologies
Rules and scenarios: static thresholds, lists of countries/methods, velocity-checkers.
Machine learning: anomaly models and scoring by cohort and time.
Graph analytics: identifying links between accounts (shared devices, IP, payments).
POP/sanction screeners: automatic reconciliations with lists.
Case-management: a single window for alerts, notes, documents and solutions.
Device-/IP intelligence: proxy/VPN/emulators, TOR flags, ASN risk.
Typical red flags in the casino
Smurfing: Frequent deposits/withdrawals in small portions to bypass thresholds.
Fast turnovers without game logic: replenishment → minimum bet → withdrawal.
Transit accounts: "running" funds through a casino without real gameplay.
Profile mismatch: Low-income student - large and stable deposits; VIP without SoF confirmation.
Related devices: a network of accounts with the same device ID, IP, cards.
A sharp change in geography: entries and payments from different countries in a short time.
Suspicious payment routes: mix of third-party cards, rare wallets, "mules."
Crypto anomalies: replenishment from mixers, "freshly created" wallets without history, bridges from sanctions clusters.
AML and cryptocurrencies in iGaming
Chain analysis: risk assessment of incoming/outgoing transactions, mixer flags, darknet clusters, sanctions.
Travel Rule: for large/cross-platform transfers within jurisdictional requirements.
Proof-of-Funds: at high volumes, the operator requests SoF/SoW (statements, asset sales agreements, dividends).
Risk by assets: stablecoins vs. highly volatile assets, on-chain labeling.
Suspicious Activity Reports (SAR/STR)
If the customer's behavior or transaction appears to be economically unexplained and/or contradicts the risk profile, the operator generates an internal report. After verification by compliance, an official message is sent to the appropriate authority (the format and timing depend on the license). The client is not notified ("tipping-off" prohibition).
Roles and responsibilities (3 lines of defense)
1. Business/operations: compliance with procedures, initial identification, correct data.
2. Risk and compliance: rules, monitoring, investigations, reports, training.
3. Internal Audit/Independent Evaluation: AML Program Performance Review, Design and Operational Performance Tests.
AML Program Performance Metrics
The proportion of alerts transferred to cases and confirmed cases.
Case processing time and completeness of documentation.
Quantity and quality of SAR/STR without "false noise."
Coverage of sanctions/RAP checks and relevance of lists.
Results of independent audit and regulatory inspections.
Frequent misconceptions
"AML is KYC only." No: KYC - input filter; AML - additional dynamic protection after onboarding.
"One rule is enough." You need a combination of rules, ML models, graph and manual expertise.
"Crypto = always high risk." Risk is differentiated by assets, sources, behavioral patterns, and on-chain valuations.
"If the client is VIP, he can do anything." On the contrary: the limits above are stricter than EDD and SoF/SoW.
Practice for operators: where to start and what to strengthen
Update the BWRA annually and with product/geographic map changes.
Segment customers (low/medium/high risk) and associate segments with limits and EDD procedures.
Combine detectors: rules + ML + graph. Retrain the models periodically.
Debug case management: clear SLAs, solution checklists, document request templates.
Teach commands: front, payments, VIP managers - everyone should understand red flags.
Vendor-risk: Evaluate external data/screening providers, perform pentests and SLA checks.
Tips for players: how to avoid delays and unnecessary requests
Go KYC in advance: correct name/address, valid documents.
Use payment methods in your name: do not mix cards of relatives/friends.
Explain major transactions: Keep statements/docking grounds for SoF/SoW.
Play from a single device/location: Avoid frequent IP/VPN changes.
Keep your communication history: if compliance asks for documents, respond promptly.
Mini-FAQ
How is AML different from KYC?
KYC confirms the identity and basic data of the client; AML tracks what and how a customer does with money throughout an account's life.
Why was I asked for a "source of funds" if I had already passed KYC?
Because payment volumes/patterns increased risk. This is standard EDD practice, not an accusation.
Can the output be frozen for the duration of the check?
Yes, if AML triggers are triggered or additional documentation is required. Once confirmed, the funds will be released.
Is the client informed about the submission of a suspicious report?
No, it isn't. The law generally prohibits disclosing the fact of filing a SAR/STR.
AML in online casinos is not a "barrier for the sake of a barrier," but a systemic protection of the industry and players: from risk assessment and KYC to smart monitoring, reporting and team training. For operators, a high-quality AML program is a guarantee of a license and partnerships; for players, ensuring that winnings are handled in a legal and transparent loop.