🧊 Introduction
Hi there,Welcome to this week’s edition of Polar Insider. This issue explores how criminals launder illicit funds through pokies (slot machines) and casinos. Despite growing regulatory attention, pokies remain a persistent weak point for financial crime, offering anonymity and ease of cash conversion.
📌 Top Story – Laundering via Pokies🔎 Case Study – Bangladesh Bank Heist – Laundering Through Philippine Casinos🌍 Regulatory Roundup🧰 Compliance Toolkit
📌 Top Story
Laundering via Pokies
Pokies (slot machines) are among the most exploited tools for laundering illicit funds. Their cash-heavy, decentralized, and anonymous nature makes them particularly attractive for criminals seeking to disguise dirty money as gambling winnings.
🔎 Why it works: Pokies are cash-intensive, decentralized, and fast-moving. Unlike casinos with centralized surveillance, thousands of pubs and clubs provide weak points in the AML chain.
The Risk to Financial Institutions
For compliance teams, pokies present layered risks:
Fragmentation: Thousands of venues make it difficult to detect coordinated laundering.
Regulatory Gaps: Smaller pubs and clubs may face lighter compliance rules, offering loopholes.
False Legitimacy: Banks often accept “gambling winnings” as a plausible source of wealth, giving launderers cover.
What You Can Do
Here are 5 key strategies compliance teams can deploy:
✅ Enhanced EGM Monitoring – Track cash-in vs. play ratios; flag >90% cash-outs with little play.✅ Structuring Detection – Identify multiple small redemptions by the same ID or group.✅ Loyalty Card Analytics – Investigate heavy loading/unloading inconsistent with real play.✅ Cross-Venue Intelligence – Share data across venues to spot hopping or networks.✅ Staff Training – Teach venue staff to recognize “cash-in, no play” behavior and report it.
🧠 Pro Tip: The cash-in vs. play ratio is the clearest early red flag — build it into monitoring dashboards.
🔎 Case Study
Bangladesh Bank Heist – Laundering Through Philippine Casinos
In February 2016, hackers (allegedly linked to North Korea’s Lazarus Group) stole USD 101 million from the Bangladesh Bank’s Federal Reserve account in New York. While some transfers were stopped, USD 81 million flowed into the Philippines and was laundered through its casino sector.
Here’s how the six pokies typologies played out:
1. Cash-In, Minimal Play, Cash-Out
Stolen funds were withdrawn in pesos and brought into Manila casinos. Launderers converted them into gaming chips and slot credits, played minimally, and quickly cashed out.➡️ Only a fraction of the USD 81m was actually “played” in games; most was churned briefly before redemption.
2. Structuring Across Machines & Venues
Funds were split into smaller tranches and spread across several casinos, including Solaire Resort & Casino and Midas Hotel Casino.➡️ Dispersing deposits avoided a single large red flag.
3. Third-Party Laundering (Mules)
Funds were passed through junket operators and local businesspeople acting as conduits.➡️ Junket operator Kim Wong was accused of receiving and moving part of the funds.
4. Loyalty Cards & Gaming Accounts
Casino accounts allowed money to be recorded as player activity. Funds cycled through electronic gaming machines, later withdrawn as winnings.➡️ Accounts provided a veneer of “legitimate gambling turnover.”
5. Venue Hopping
The laundering didn’t happen in one casino alone. Funds were moved between multiple Manila casinos and junket rooms in a short timeframe.➡️ USD 29m flowed into Solaire, another USD 21m into Midas, fragmenting the trail.
6. Integration Through ‘Lucky Wins’
Once cashed out, funds were claimed as “gaming winnings” and then layered into the economy.➡️ Some proceeds went into Philippine real estate and construction projects. Only USD 15m was ever recovered.
Investigators traced the stolen funds through multiple casinos and junket accounts. Only USD 15m was recovered, with the rest vanishing overseas. The scandal exposed the Philippines’ lack of AML coverage for casinos at the time. In response, lawmakers amended the AMLA in 2017 to include casinos, RCBC was fined, and compliance obligations tightened across the sector.
Why it matters: Casinos and slot machines enabled placement, layering, and integration in one ecosystem. Weak AML laws at the time (Philippine casinos were not covered by AML rules in 2016) created the perfect laundering gap.
Key Lessons for Financial Crime Teams
🚨 Casinos enable placement, layering, and integration in one step – controls must span all three.🔐 Regulatory gaps invite exploitation – AML obligations must cover casinos and gaming venues.🧱 Cross-border intelligence sharing is vital – once funds leave the banking system for casinos, recovery becomes nearly impossible.
🌍 Regulatory Roundup
🇺🇸 North America
FinCEN requires casinos to file Currency Transaction Reports for cash ≥ USD 10k and SARs for suspicious patterns.
Recent enforcement actions fined U.S. cardrooms nearly USD 1m for failing to detect minimal-play and structuring schemes.
🇬🇧 Europe (United Kingdom)
UK Gambling Commission fined William Hill (£19.2m) and Entain (£17m) for failing to monitor source of funds.
In 2025, an Alderney-based operator was fined £1m for AML lapses in online gambling.
🇦🇺 Asia-Pacific (Australia)
AUSTRAC fined SkyCity Adelaide AUD 67m and has launched cases against large clubs like Mounties.
States are moving toward cashless cards to end anonymous play.
🇵🇭 Asia-Pacific (Philippines)
Amended AMLA now requires casinos to report transactions ≥ PHP 5m.
The country remains on the FATF grey list due to junket risks.
🇸🇬 Asia-Pacific (Singapore)
Casinos must conduct KYC for cash transactions ≥ SGD 4k.
Regulators cite casinos as well-controlled but remain vigilant.
🇱🇦 Asia-Pacific (Laos)
FATF grey-listed Laos in 2025, highlighting casino laundering risks in its Golden Triangle SEZ.
Key Message: Casinos and pokies are global weak points. Regulators are closing loopholes, but enforcement consistency remains a challenge.
🧰 Compliance Toolkit
Equip yourself with these resources to tackle financial crime in gaming and betting effectively:
• AUSTRAC – Guidance for pubs, clubs, and casinos📎 Pubs and clubs | AUSTRAC
• FATF – Vulnerabilities of Casinos and Gaming Sector📎 Vulnerabilities of Casinos and Gaming Sector
• UNODC – Casinos & Crypto Laundering Networks in Southeast Asia📎 Casino_Underground_Banking_Report_2024.pdf
• UK Gambling Commission – Source of Funds Guidance📎 https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/source-of-funds-evidence
💬 Quote of the Week
“Pokies are a laundromat in plain sight — the challenge is building controls strong enough to clean the system, not the cash.”
🎁 Bonus for Subscribers
Don’t forget to download your copy of the 2025 Financial Crime Regulatory Tracker (USA, UK, AU).
Stay on top of AML requirements and enforcement trends globally.
