The Financial Action Task Force (FATF) has released a report titled Risks of Gaming and Gambling, outlining various risk indicators related to money laundering in the gambling sector. This comprehensive study is based on surveys from 80 jurisdictions within the FATF global network, written comments from 29 jurisdictions, and case studies provided by them.
Here are some key findings regarding online gambling:
Player Risk Indicators:
- Repeated use of VPNs, multiple devices, and discrepancies between declared residence and actual location.
- Changing IP address locations with each account login.
- Account data not matching payment method details for deposits and withdrawals.
- Multiple accounts under different names from a single IP address or device.
- Withdrawal of funds shortly after deposit without significant gaming activity.
- Refusal to participate in video calls for identity verification.
- Regular withdrawals of winnings just below the threshold requiring verification.
- Deposits below the threshold that operators must report to regulators.
- Bets on all possible outcomes of a single event.
- Anomalies in P2P games, where one player consistently loses to another.
- Bets placed by individuals connected to the sport they are betting on (referees, players, coaches, club and federation staff).
Operator Risk Indicators:
- Excessive reliance on third-party providers and white label solutions.
- Promotion of products in countries where online gambling is prohibited.
- Transactions in virtual assets with suppliers and partners.
- Frequent changes to website URLs, company names, or brands.
- Economically unjustified contracts with software, marketing, and consulting service providers.
- Complex cross-border ownership structures that obscure ultimate beneficiaries.
- Accepting player payments through accounts registered for other business activities.
- Sharp increases in revenue or player numbers without a corresponding scale of business operations.
- Obtaining a license followed by a prolonged absence of operational activity.
FATF emphasizes that this list is not exhaustive, and a single indicator does not necessarily indicate money laundering but serves as a basis for further monitoring. Some indicators may reflect problematic gaming behavior rather than intent.