1. Game-Specific Money Laundering Risks
Table Game Vulnerabilities
Slot Machine Considerations
- Minimal play before large cashout
- Multiple machines used by same player
- Coordination between players on adjacent machines
2. Behavioural Monitoring on Casino Floor
Suspicious Behaviour Indicators
- Avoidance Behaviour: Staying away from surveillance areas
- Communication Patterns: Signals between players
- Playing Patterns: Intentional losses, irrational bets
- Chip Movement: Unexplained transfers between players
Documentation Requirements
- Incident Reports: Detailed descriptions of suspicious behaviour
- 5W1H Method: Who, What, When, Where, Why, How
- Evidence Preservation: CCTV timestamps, witness statements
3. Chip Transaction Controls
Chip Dumping Identification
Definition: Intentional loss of chips to another player to transfer value
Detection Methods
- Monitoring bet patterns against basic strategy
- Tracking chip movement between associated players
- Analyzing win/loss ratios for abnormalities
Chip Walking Prevention
- Supervision of chip transfers between tables
- Documentation of large chip movements
- Verification of play before large cashouts
4. Collusion and Chip Dumping Detection
Common Collusion Techniques
- Signal Systems: Hand signals, betting patterns as communication
- Soft Play: Intentional weak play against accomplices
- Chip Passing: Physical transfer of chips between collaborators
- Information Sharing: Sharing knowledge of hidden cards
Prevention Measures
- Regular dealer training on detection techniques
- Surveillance coordination for suspect tables
- Player behaviour analysis software
- Table rotation policies for staff
5. Progressive Jackpot Compliance
Large Win Protocol
- Immediate Verification: Confirm win legitimacy
- Customer Identification: Full CDD regardless of amount
- Source of Funds: Verify funds used to play
- Enhanced Documentation: Complete win package
- STR Consideration: Assess for suspicious circumstances
Tax and Reporting Requirements
- Withholding tax calculations per Sri Lankan law
- CTR filing for cash payments above LKR 10M
- International winner reporting for foreign nationals
- Coordination with Accounts department for payment processing
6. Gaming Red Flag Dictionary
Blackjack-Specific Indicators
“Intentional Busting”
- Definition: Player deliberately exceeds 21 when holding strong position
- Detection: Player hits on 18-20 against dealer’s weak card
- Why It Matters: Method to lose chips to accomplish partner
- Action: Document pattern, notify surveillance, prepare STR
“Maximum Bet Losses”
- Definition: Placing maximum bets then making worst possible decisions
- Detection: Consistent play against basic strategy
- Why It Matters: Rapid fund transfer disguised as gambling
- Action: Monitor for receiving party, file STR
Roulette-Specific Indicators
“Opposite Outcome Betting”
- Definition: Two players betting opposing outcomes (red/black, odd/even)
- Detection: Coordinated betting through accomplices
- Why It Matters: Covers the board to guarantee one win, transfers value
- Action: Identify both players, link transactions, STR filing
Poker Tournament Red Flags
“Soft Play Collusion”
- Definition: Player intentionally folds strong hands to eliminate competitors
- Detection: Irrational folding patterns, communication signals
- Why It Matters: Manipulates tournament to benefit accomplice
- Action: Review hand history, tournament disqualification, STR
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