AML / CFT
AML/CFT regime, FATF status, SAR/CDD obligations, sanctions and UBO/reporting duties.
27 further jurisdictions with flags in this theme are in expert review and not shown until published.
Cross-jurisdiction posture cluster
135 flags across 81 jurisdictions. Posture mass: Rules 37 · Risks 72 · Reality 26.
Worked examples
Each links back to the full jurisdiction page — the theme view is a projection of those country ledgers.
FATF blacklist counter-measure posture; mandatory enhanced due diligence.
Any US-person involvement in Venezuela gambling flows is potentially an unauthorised transaction.
AUSTRAC record civil penalties (Crown 450M, Star 400M sought).
Rules · Risks · Reality across the cohort
Online casinos and bookmakers are designated reporting entities under UIF Res. 194/2023.
AUSTRAC record civil penalties (Crown 450M, Star 400M sought).
Star Sydney licence suspended pending remediation.
FinCEN Huione designation; severe AML/scam-compound exposure.
AMLA 2010 designates gambling proceeds as proceeds of crime.
Any counterparty relationship with the designated group or its affiliates carries direct US sanctions exposure.
FATF blacklist counter-measure posture; mandatory enhanced due diligence.
OFAC TCO designation; asset freeze and US financial-system exclusion.
OFAC E.O. 13818 designations for human rights abuse.
Compounds use casino functions to launder scam proceeds.
Core failing in the SkyCity case.
Designated predicate offence under AML Law 2012 (amended 2022).
Casinos >$1M GGR are financial institutions; $25,000/day penalty and criminal exposure.
Any US-person involvement in Venezuela gambling flows is potentially an unauthorised transaction.
Mandatory enhanced due diligence on all Venezuela-connected flows.
Any linked payment risks material-support liability — catastrophic exposure.
FINTRAC AMPs (e.g. SIGA C$1.175m) demonstrate active federal AML enforcement against gaming entities.
EDD required on all Algeria-connected flows; correspondent-banking friction.
Self-assessment was due to UIF by 30 April 2024 and must repeat biennially.
Federal BSA obligations apply with $10,000 CTR threshold.
Severe AML typology exposure for any PSP touching BD flows.
Systemic designation drives transaction-monitoring deployment.
FINTRAC fined even BCLC >C$1M; AML now core IGCO mandate.
Mandatory EDD on Cameroon-connected flows; banking and PSP de-risking risk.
Low execution rate signals prolonged grey-list status.
Operators are designated reporting entities; FINTRAC oversight with criminal exposure.
Capital outflow and money-laundering typology cited by SPC; AML Law 2025
Engages AML Law 2025 and Art. 287-2
Operators are designated reporting entities; AML failures draw federal exposure.
Indicates an active typology of using Comorian banking identifiers to lend false legitimacy to offshore financial flows, which is directly relevant to any gambling-adjacent payment rail touching Comoros.
No designated national reporting-entity regime for gambling exists in practice; GIABA MER flags weak DNFBP supervision nationally.
Historical pattern of BCC legal action and international rogatory commissions against Anjouan offshore financial entities signals elevated correspondent-banking and sanctions-screening risk.
Gambling operators are not SUGEF-obligated entities — minimal AML standing.
Offshore gambling hubs cited in AML typologies affecting all CR-based entities.
Operators are designated obligated subjects supervised by UAF.
Documentation/response in Estonian required; missed deadlines drew fines.
Enhanced FIU reviews and source-of-funds expectations.
AMLR applies directly and automatically; no national transposition grace period exists
OSCO s.25 money-laundering prosecution
Operation SOGA-type international enforcement waves
BSA/FinCEN obligations apply; non-filing is a federal violation.
PPATK tracing exposes operators and players to money-laundering charges.
FIA traces betting financial transactions and prosecutes facilitators.
Elevated AML posture after October 2022 exit; scrutiny remains.
SBP forex rules prohibit gambling remittances.
Mass arrests in 2023–2024; AML exposure inside casinos
Money-laundering exposure attaches to all gambling cash flows.
Operators are designated reporting entities.
Federal AML obligations apply to casino covered persons.
Enhanced due diligence required; blacklisting risk per APG.
Blacklisting would severely disrupt banking/remittance access.
Cash-intensive environment; NGCB conducts independent AML audits.
Casinos are federal reporting entities.
MLPPA 2022 designates casinos as DNFBPs
KoFIU STR regime; predicate offence.
Individual deposits/withdrawals above ~1,175,000 RSD/30 days restricted.
Mandatory under Ley 10/2010; designated reporting entity obligations.
Junket operators must keep complete patron/financial records and report suspicious activity.
Confiscation and money-laundering exposure across the value chain.
Licensees are DNFBPs with bank-grade CDD, EDD, STR and five-year record-keeping obligations.
CTR (>$10,000) and SAR (≥$5,000) reporting are mandatory federal obligations.
Financial institutions must still file SARs on Venezuela activity.
Cross-border settlement effectively severed.
Counterparties with those connections void any GL reliance.
AiGC, not AGLC, is the Alberta-side contact for AML-process and financial reporting.
Res. 194/2023 makes a substitute compliance officer mandatory.
Civil penalty proceedings (Castra, Princeton 2025).
Operators are designated reporting entities with CDD duties.
SoF beyond PCMLTFA thresholds are operator-level risk decisions.
Prosecuted under Art. 303 where profit-oriented
Operators are designated reporting entities with SAR/CTR duties.
Misstatement carries licence and criminal risk.
Ongoing CDD/STR/PEP compliance burden.
Compliance teams relying on the 2009 originals without checking the AGCC consolidated/amendment stack risk non-compliance.
Banking access risk can constrain operational viability even for fully licensed entities.
AML/CFT obligations apply and AML provisions were amended in 2025.
FRC reporting obligations and penalties up to KES 5m.
Heightened AML enforcement exposure for operators.
Absence of specialised gambling-sector AML supervision may create compliance-monitoring gaps for the two obliged-entity operators.
Heavy AML/CFT obligation lift except Type 4-only.
Monthly remittance to the state is required.
Paper law; no enforcement capacity; does not reduce blacklist risk.
APG questioned amendment process; regime in flux.
Operators are designated reporting entities with full AML programmes.
DIA raised continuous-play concerns in the SkyCity review.
SAR/CTR filing obligations apply; OCCC also requires AML programme.
Indicates historical AML/CFT framework weakness relevant to banking/payments counterparty risk
Monthly GGR/player reports are mandatory; non-filing risks sanction.
Grey-list exit recent; maintaining standards required.
SAR/CTR filing obligations on contractors.
Operators are designated reporting entities; SA FATF grey-list context
A low CDD threshold increases the volume of transactions subject to due diligence, raising compliance-system burden once licensing commences.
Heightened compliance scrutiny and potential enforcement risk.
Affects levy calculation and compliance standing.
The April 2026 NPRM proposes a shift to effectiveness-focused programs that would require re-engineering if finalised; no final rule has yet been published.
Independent testing must be conducted by gaming-AML-qualified reviewers.
Gambling entities face robust AML/CFT obligations among the strongest in South America.
Host-jurisdiction licences may be pressured over Venezuela exposure.
AML programme and OFAC screening are mandatory irrespective of small scale.
Compliance scoping uncertainty for designated reporting entities.
Residual diligence gap on AML-list standing.
State-level AML detail thin; relies on federal baseline.
Compliance scoping risk for any authorised operator.
SAR/CTR obligations on operators as MSBs/casinos.
Dual federal/state AML supervision for payment partners.
Standard AML compliance required of reporting entities.
Senegal was grey-listed 2021-2024; residual EDD posture in some banks may persist.