Myth: Online gambling is more susceptible to money laundering than land-based
gambling.
Fact: “There is no credible evidence of money laundering
associated with online gambling. Land-based gambling in venues
such as casinos and race tracks is more susceptible to money laundering
than online gambling. United States government studies have concluded
that it is unlikely that online gambling can be used for money
laundering because there are no anonymous cash transactions in
an online gambling transaction, unlike in land-based casinos
where money laundering has been, continues to be, a concern.
Details: While United States officials frequently contend that
online casinos and sportsbooks are susceptible to money laundering,
they have never cited an actual example of such activity. If
money laundering in online gambling was as apparent as these
officials claim, then, by their logic, any foreign business could
be shut down for money laundering on mere allegations of such
activity. There is no money laundering in the online gambling
industry. The United States has issued official government studies
concluding that online gambling is not a likely or accessible
avenue for money laundering because the identities of the gamblers
are known, the financial transactions between the bettors and
operators are all in an electronic format, and all of the wagering
is recorded. By contrast, land-based casinos in the United States
have had documented incidents of actual money laundering due
to the large volume of anonymous cash transactions taking place
at casinos. Within the last two years, money laundering scandals
have erupted in the United States land-based casino industry,
such as the case of large casinos failing to complete anti-money
laundering forms for winning customers and a criminal syndicate
from Japan laundering money through Nevada casinos. The United
States government alleged that a group of alleged Muslim terrorists
in Buffalo, New York were laundering money through a local casino.
To the extent there is a legitimate concern about money laundering
in the gambling industry, the concern could be resolved by encouraging
the use of credit cards and other secure forms of electronic
payments for online gambling and regulation of the online gambling
industry. That way, there would be a regulated system that ensured
an “electronic footprint” in all gambling transactions.
This would eliminate any remote risk of money laundering in the
online gambling industry.
References: United States General Accounting Office, Money Laundering: Rapid
Growth of Casinos Makes Them Vulnerable, GAO/GGD-96-28 (4 January
1996)
United States General Accounting Office, Money Laundering: Extent
of Money Laundering through Credit Cards is Unknown; GAO-02-670
(22 July 2002). This report states: “The extent to which
money laundering through credit cards may be occurring is unknown.
Bank regulators, credit card industry representatives, and law
enforcement officials we interviewed generally agreed that credit
card accounts were not likely to be used in the initial stage
of money laundering when illicit cash is first placed into the
financial system, because the industry generally restricts cash
payments. Bank regulators and credit card industry representatives
we interviewed acknowledged that credit card accounts might be
used in the layering or integration stages of money laundering.
For example, by using illicit funds already placed in a bank
account to pay a credit card bill for goods purchased, a money
launderer has integrated his illicit funds into the financial
system. Most law enforcement officials we met with were unable
to cite any specific cases of credit card–facilitated money
laundering in U.S.–based financial institutions. Further,
a FinCEN analysis of its database of SARs filed by U.S.-based
financial institutions revealed very little evidence of potential
money laundering through credit cards.”
United States General Accounting Office, Internet Gambling:
An Overview of the Issues, GAO-03-89 (2 December 2002). With
respect to money laundering, this report states: “Representatives
of law enforcement agencies, regulatory bodies, and the credit
card and gaming industries expressed mixed views regarding the
vulnerability of Internet gambling to money laundering. Law enforcement
officials said they believed that Internet gambling could potentially
be a powerful vehicle for laundering criminal proceeds at the
relatively obscure layering stage of money laundering . . . Law
enforcement officials acknowledged the lack of adjudicated cases
involving money laundering through Internet gambling sites but
cited what they believed to be contributing factors, including
the lack of any industry regulations or oversight. Banking and
gaming regulatory officials did not view Internet gambling as
being particularly susceptible to money laundering, especially
when credit cards, which create a transaction record and are
subject to relatively low transaction limits, are used for payment.
Likewise, credit card and gaming industry officials did not believe
Internet gambling posed any particular risks in terms of money
laundering. Gaming industry officials did not believe that Internet
gambling was any more or less susceptible to money laundering
than other types of electronic commerce and pointed out that,
in their view, the financial industry, which is responsible for
the payments system, is better suited to monitoring for suspicious
activity in the area than the gaming industry itself.” (emphasis
supplied)
American Gaming Association, Fact Sheet: Money Laundering.
CasinoWatch.Org [Anti-Gambling Advocacy Group], “Money
Laundering in Casinos.” This site documents a number of
money laundering incidents in United States land-based casinos.
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