Casino Malta was fined EUR233.834 (PS206.633/$249.510) for numerous anti-money laundering (AML/CTF).
Casino Malta was fined by the Financial Intelligence Action Unit , a government agency charged with fighting money laundering and terrorist financing.
The FIAU referred to one instance where a CEO of a company, who had connections in Turkey, was able spend EUR1m at Casino Malta without the operator verifying the source of funds.
The majority of the money was in cash and was summoned using eight different bank accounts.
Notes were attached to the customer’s player profile. This required that his identification documentation be taken on his next visit. No notes were made that mentioned collecting source of funds documentation or information.
“The company should have carried out additional measures such as obtaining documentation as to this player’s source of wealth (SOW) as well as the income earned, and other returns generated through his employment/businesses,” read the FIAU’s report.
Another incident involved a student who had connections to China and was able to spend EUR200,000 and then lose EUR80,000 between January 2019-December 2019 without having to check any sources of funds.
The FIAU said that the case was reviewed and it did not provide any assurances as to how a student could be able to afford such a large gaming activity/deposit within a short time.
Problematic
The FIAU committee also highlighted problems with the casino’s internal classification of risk. The committee noted that 22% of player profiles that were assigned a low- or medium risk rating performed transactions that they would not expect.
“The committee stated that customer activity should have prompted the company to update its risk rating and to take the appropriate enhanced measures to manage these risks.
A player who has a valid bank account is often considered low- or medium-risk, regardless of the nature of their bets.
One customer spent EUR2m and lost EUR900,000. Between 2016 and 2019, one customer made EUR2m. The FIAU stated that it was important to ensure funds come from a legitimate bank account. However, this does not guarantee total mitigation of individual risks.
Failure To Report
The FIAU highlighted specific issues in the casino’s internal procedures throughout the report. The committee claimed that the casino’s guidelines didn’t provide enough instruction to employees on what they should do when reporting suspicions of money laundering.
One case showed that a person who claimed to be a “plasterer”, was able, despite being in court for drug trafficking and having a freezing order in place, to gamble large amounts of money at the casino.
The FIAU stated that “the company, even though it was unaware of the freezing orders, knew about the ongoing court proceedings against customer.” “Despite this, the company did not submit a suspicious transaction report to the FIAU and allowed the player to continue to wager large amounts.”
Another case involved a politically exposed person (PEP), who registered at the casino. Despite their status, they were deemed low-risk. After the company checked the player, it was discovered that the individual had been involved in bribery as well as tax evasion.
“Despite this discovery, the customer was allowed to continue betting large amounts of cash. Despite all this, the company did not submit an STR for the FIAU.