AML for Casinos and Gaming Operators Training Course

Duration 5 days 10 modules · 33 contact hours
Level Intermediate Certificate on completion
Who attends AML Compliance Managers, MLROs and Deputy MLROs and others
Fee from USD 1,100 KSh 95,000 for Kenyan organisations
Where 52 cities + online See dates by city
Next start 16 Nov 2026 Course code SD-FFC-025

Before you join: Participants should understand basic AML concepts such as customer due diligence, suspicious activity reporting and record retention.

Dates & prices

Two start dates a month in every city, and live online on weekdays or weekends. Fees are per participant; classroom fees include tuition, materials, lunch and refreshments, and the certificate.

Suggest a date or city

Showing the next six months. Later dates, other cities and private deliveries for your team are available on request.

Course overview

Casinos and gaming operators handle high transaction volumes, cash, prepaid instruments, remote payments, third-party activity and rapid movement of value. These features can be exploited to place, layer or disguise criminal proceeds through chip purchases, structured cash activity, minimal-play gaming, linked accounts, VIP arrangements, junket relationships and suspicious withdrawals. Compliance teams must identify risk without treating legitimate gambling behaviour as suspicious by default, while maintaining records and reporting decisions that withstand regulatory scrutiny.

This course examines anti-money laundering controls for land-based casinos, online gaming operators, sportsbooks and related gaming businesses. Participants apply the FATF risk-based approach to customer risk assessment, customer due diligence, source-of-funds enquiries, transaction monitoring, suspicious activity reporting, sanctions screening and third-party risk. The programme also addresses casino-specific typologies, including chip conversion, cash structuring, collusive play, proxy betting, mule accounts, bonus abuse and payment-method misuse.

Instruction combines focused briefings with case analysis, group reviews of customer files, transaction-monitoring scenarios, suspicious activity narrative drafting and control-design discussions. Participants work with realistic casino and online gaming fact patterns, testing escalation decisions against stated risk indicators and evidence standards. They leave with a reusable AML control toolkit containing a casino risk-assessment model, customer due diligence checklist, transaction-monitoring rule set, investigation case-file template, suspicious activity report structure and 90-day improvement plan.

The course is suited to AML, compliance, risk, audit, operations and gaming-management professionals who already work with regulated customer transactions. It is particularly relevant for teams responsible for building or reviewing controls across gaming venues, remote gaming platforms, payment channels and VIP customer programmes.

What you will be able to do

  • Assess casino and gaming money-laundering risks using a FATF-aligned risk assessment
  • Classify customers using documented risk-rating factors and enhanced due diligence triggers
  • Apply source-of-funds and source-of-wealth enquiry methods to high-risk gaming activity
  • Design transaction-monitoring rules for casino, sportsbook and online gaming red flags
  • Investigate suspicious gaming transactions using evidence logs, timelines and escalation criteria
  • Draft defensible suspicious activity reports based on clear facts and reasonable grounds
  • Evaluate AML control gaps across customer onboarding, payments, VIP services and cash operations
  • Produce a prioritised 90-day AML remediation plan for a gaming operation

Benefits of attending

For you

  • Make better-supported escalation decisions on unusual gaming and payment activity
  • Build credible source-of-funds enquiries for high-value or high-risk players
  • Recognise casino-specific laundering patterns before they become regulatory findings
  • Write clearer suspicious activity narratives with documented rationale and evidence
  • Contribute practical control improvements to AML audits, reviews and remediation programmes

For your organisation

  • Reduce exposure to laundering through cash, chips, remote accounts and payment channels
  • Improve consistency of customer risk ratings and enhanced due diligence decisions
  • Strengthen suspicious activity investigations with clearer evidence and audit trails
  • Identify control weaknesses in VIP, junket, cage and online gaming processes
  • Prioritise AML remediation actions against material regulatory and licence risks

Course modules

10 modules over 5 days

Participants can identify casino and gaming features that create money-laundering exposure.

  • Casino money-laundering typologies: cash buy-ins, chip conversion, collusion and refunds
  • Three stages of laundering mapped to land-based gaming transactions
  • Online gaming flows: deposits, wagers, withdrawals, bonuses and payment intermediaries
  • FATF risk-based approach and national casino control obligations
  • Criminal proceeds indicators involving junkets, agents, VIPs and third parties
  • Distinguishing customer gambling losses from transactions designed to obscure value
  • Regulatory consequences: licence exposure, enforcement actions, penalties and reputational damage

Participants can structure a documented AML risk assessment for a gaming operation.

  • Enterprise AML risk assessment using customer, product, channel and geography factors
  • Inherent-risk scoring for land-based, online, sportsbook and lottery activities
  • Control-effectiveness assessment using design, operation and evidence quality criteria
  • Residual-risk ratings linked to management actions and review frequencies
  • Risk appetite statements for cash thresholds, VIP services and payment methods
  • Governance roles: board oversight, MLRO authority, operations ownership and assurance
  • Documenting assumptions, data limitations and risk-assessment challenge records

Participants can apply proportionate due diligence and customer risk-rating controls.

  • Customer identification requirements for patrons, account holders and legal entities
  • Beneficial ownership checks for corporate players and related-party accounts
  • Risk-rating models using occupation, geography, transaction behaviour and adverse information
  • Enhanced due diligence triggers for politically exposed persons and high-value players
  • Ongoing due diligence schedules matched to customer risk and activity
  • Documenting purpose-of-account information for remote gaming customer relationships
  • Managing refusal, incomplete evidence and customer offboarding decisions

Participants can assess whether a customer's gaming funds are consistent with known circumstances.

  • Source-of-funds versus source-of-wealth: distinct questions and evidence standards
  • Evidence hierarchy: bank statements, contracts, sale documents and tax records
  • Reasonableness testing against customer profile, declared income and transaction pattern
  • Analysing third-party funding, shared payment instruments and linked customer accounts
  • VIP customer reviews: expected play, credit arrangements and host interactions
  • Escalating unverifiable explanations through documented challenge and approval routes
  • Recording proportionality decisions without collecting unnecessary personal information

Participants can identify and control laundering risks in land-based casino operations.

  • Cage procedures for cash buy-ins, chip redemptions and monetary instrument purchases
  • Structuring indicators around reporting thresholds, linked visits and multiple cashiers
  • Minimal-play patterns following high-value chip purchases or cash deposits
  • Chip-walking, chip transfers and third-party redemption risk indicators
  • Table-games observation records supporting unusual transaction investigations
  • Casino credit, markers and front-money accounts within AML control frameworks
  • Reconciling surveillance, cage, loyalty and gaming-floor data for investigations

Participants can detect financial-crime risks arising from remote gaming and payment activity.

  • Remote onboarding controls: identity verification, liveness checks and device intelligence
  • Deposit and withdrawal patterns indicating mule accounts or account takeover
  • Payment-method risk: prepaid cards, e-wallets, virtual assets and chargebacks
  • Bonus abuse indicators involving linked accounts, devices and payment credentials
  • Proxy betting and collusive play signals within sportsbook and poker activity
  • Geolocation controls for restricted jurisdictions and suspicious location changes
  • Withdrawal controls for rapid cash-out, third-party payments and account changes

Participants can design and triage monitoring alerts using risk-based thresholds and scenarios.

  • Scenario design using customer behaviour, transaction value, velocity and relationships
  • Threshold rules calibrated for cash, chip, deposit and withdrawal activity
  • Peer-group analysis comparing play patterns against similar customer segments
  • Alert triage using risk scores, prior cases and linked-account information
  • Reducing false positives through segmentation, suppression logic and quality review
  • Case-management evidence logs capturing queries, documents, decisions and approvals
  • Monitoring coverage tests for data completeness, timing and interface failures

Participants can investigate suspicious activity and prepare a defensible reporting rationale.

  • Investigation planning: allegation, scope, evidence sources, ownership and deadlines
  • Transaction timelines connecting deposits, wagers, wins, losses and withdrawals
  • Reasonable-grounds analysis separating suspicion, proof and unsupported assumptions
  • Suspicious activity narratives structured around who, what, when, where and why
  • Tipping-off restrictions and controlled communications with customers and staff
  • Management information for report volumes, ageing, outcomes and thematic trends
  • Post-report account actions: monitoring, restrictions, exit decisions and record retention

Participants can manage sanctions, PEP and intermediary risks in gaming relationships.

  • Sanctions screening for customers, beneficial owners, payees and connected parties
  • Potential-match investigation using identifiers, ownership data and documented disposition
  • PEP identification, senior approval and enhanced monitoring requirements
  • Junket, affiliate and agent due diligence using ownership and reputation checks
  • Third-party payment controls for corporate arrangements and customer representatives
  • Adverse media assessment distinguishing credible allegations from unverified information
  • Escalation protocols for sanctions hits, PEP changes and intermediary concerns

Participants can test AML controls and prioritise practical remediation actions.

  • Control testing plans covering onboarding, monitoring, reporting and record retention
  • Sample selection based on risk, transaction value, control failure and customer type
  • Root-cause analysis using people, process, data, technology and governance categories
  • Issue ratings based on regulatory impact, likelihood and remediation urgency
  • Management action plans with owners, milestones, evidence and closure criteria
  • Training matrices for cage staff, hosts, dealers, analysts and senior managers
  • Ninety-day AML improvement plan aligned to residual-risk priorities

Exercises and examples are adapted to each cohort's sectors and roles.

What you take back to work

  1. Casino and gaming AML risk-assessment model
  2. Customer risk-rating and enhanced due diligence checklist
  3. Source-of-funds enquiry and evidence-review template
  4. Gaming transaction-monitoring scenario library
  5. Suspicious activity investigation case-file template
  6. 90-day AML remediation action plan

Who should attend

  • AML Compliance Managers — responsible for casino or gaming AML programme effectiveness
  • MLROs and Deputy MLROs — accountable for suspicious activity escalation and reporting decisions
  • Casino Operations Managers — oversee cash, cage, gaming-floor and VIP control execution
  • Online Gaming Compliance Officers — manage customer risk across remote onboarding and payments
  • Internal Auditors — test AML control design, evidence quality and remediation closure
  • Risk and Fraud Managers — investigate unusual player behaviour and payment-related red flags

Skills and tools covered

Casino AML risk assessmentCustomer due diligenceGaming transaction monitoringSuspicious activity reportingSource-of-funds reviewAML control testing

Tools and standards

FATF Recommendations, FATF Risk-Based Approach for Casinos, Customer Due Diligence, Suspicious Activity Reporting

How the course runs

Training methodology

The course uses short instructor briefings to establish regulatory expectations and casino-specific typologies. Participants then analyse land-based and online gaming cases, review customer files, identify red flags in transaction data and compare escalation decisions. Group exercises cover risk-rating, source-of-funds enquiries, monitoring scenarios and suspicious activity report drafting. A structured simulation follows a customer investigation from alert through disposition. Participants close by adapting the course tools into a practical improvement plan for their own operation.

Requirements and prerequisites

Participants should understand basic AML concepts such as customer due diligence, suspicious activity reporting and record retention. Experience in a casino, sportsbook, online gaming operator, payments provider, bank, audit function or financial-crime team is helpful. The course assumes confidence reading customer records, transaction data and internal procedures. It does not require prior casino-floor experience, legal qualifications, programming skills or specialist knowledge of a particular national AML regime. Participants should bring awareness of their organisation's products, customer channels and escalation arrangements where possible.

A typical training day

08:30 – 10:30First session
10:30 – 10:45Refreshment break
10:45 – 12:30Second session
12:30 – 13:30Lunch and networking
13:30 – 15:00Third session
15:00 – 15:15Refreshment break
15:15 – 16:30Workshop and daily review

Live online deliveries follow the same structure in East Africa Time, with shorter screen blocks and longer breaks.

What the fee includes

  • Instruction by a practitioner facilitator
  • Full course workbook and materials
  • Exercise files, templates and case studies
  • Refreshments and lunch on classroom deliveries
  • Certificate of completion
  • Post-course application plan

Frequently asked questions

Participants should already understand basic AML terms, customer due diligence and suspicious activity reporting. Direct casino experience is useful but not required; relevant banking, payments, fraud, audit or compliance experience is also suitable.

Bring a laptop if attending in person, plus any non-confidential AML procedures, risk assessments or monitoring questions you wish to compare with course methods. No specialist software or legal texts are required.

It is designed for AML and compliance personnel, MLROs, casino operations managers, online gaming teams, fraud managers and internal auditors. It is most useful for professionals with responsibility for customer transactions, alerts, investigations or control assurance.

General AML courses explain core obligations across financial services. This course applies those obligations to gaming-specific risks such as chip conversion, minimal play, cage activity, VIP arrangements, remote withdrawals, proxy betting and bonus abuse.

Participants can use the templates to review customer risk ratings, improve source-of-funds files, tune monitoring scenarios and assess investigation records. The final improvement plan helps convert identified gaps into owned actions and measurable milestones.

The programme provides about 32.5 contact hours, normally delivered from 08:30 to 16:30 each day. Time is divided across ten modules, with briefings, case analysis, group work, investigation simulations and action planning throughout.

Questions about this course?

Ask about dates, fees, group bookings or running it for your team. Our training team replies by email.