Red flags for casinos and online gaming

What supervisors and standard-setters expect

Casinos are treated as financial institutions in several major jurisdictions because they take cash, hold customer funds and pay out by cheque or transfer. In the US, a casino must report each transaction in currency of more than $10,000, whether cash in or cash out. Cash in includes chip purchases, front money deposits, marker payments and bets. Cash out includes chip redemptions, front money withdrawals and cheque cashing. A casino must also file a Suspicious Activity Report on a transaction or pattern of at least $5,000 that involves illegal funds, is designed to evade reporting through structuring or other means, or has no apparent lawful purpose.

Other countries set different lines. In the UK, a casino must carry out customer due diligence on any transaction of £2,000 or more, whether a stake, the purchase of tokens, a remote gambling deposit, or the collection of winnings, and including linked transactions. In Canada, a casino must report any single disbursement of $10,000 or more, and several disbursements totalling $10,000 or more within 24 hours that it knows relate to the same person. The report is due within 15 calendar days and must be kept for five years.

These duties explain why the red flags matter. Chip purchases with minimal play are about the gap between cash in and activity, which is why payouts and redemptions are tracked as closely as deposits. Junket indicators go to who the customer really is and who funds them, which is a due diligence and enhanced monitoring question. Gaming currency and skin trading indicators matter now because the FATF's September 9, 2026 report on gaming and gambling extended attention to online, illegal and video gaming, and flagged criminals moving money without actually gambling, multiple small transactions, and ownership structured to bypass regulatory check thresholds.

The clearest enforcement lesson is Australia. On July 11, 2023, the Federal Court ordered Crown Melbourne and Crown Perth to pay $450 million in civil penalties, after they admitted that their programs were not based on appropriate risk assessments, lacked adequate systems and controls, and were not subject to appropriate board and senior management oversight. AUSTRAC said Crown kept a relationship with a major junket operator until 2021 despite allegations of organised crime links, failed to monitor billions of dollars in transactions, and that from March 2016 to December 2018 there were at least 75 suspicious incidents involving about $23 million in cash in a private gaming room given to one junket operator.

As of October 2026: US and UK texts were read on the eCFR and legislation.gov.uk in October 2026; the UK page lists an amendment effective June 30, 2026. The FINTRAC page is current guidance and only about the first half of it was read; Canadian casinos have separate large cash transaction duties that were not checked here. The FATF news release for the September 2026 report was read but not the full PDF with its indicator list, so no individual indicator is quoted. The Crown figures are from AUSTRAC's July 2023 release; the Federal Court judge's comments on the adequacy of the penalty are not covered, and later developments at Crown were not checked.