December 18, 2017 Articles

New Horizons and High Stakes: Money Laundering Through Skill-Based Gaming

Electronic skill-based games are being beta tested in certain casinos, and present new challenges for casinos’ anti-money laundering programs

by Reid J. Schar, Wade A. Thomson, and Emily K. McWilliams

Three drug dealers have several thousand dollars of dirty money they want to launder. They bring their cash and a friend (with no criminal record) to the local casino in which it is now legal to play group blackjack via a mobile app. In this game, the house only takes a small rake and the majority of the pot goes to the player with the highest card total (without busting). After each of the three drug dealers cashes in some of his dirty money to get credits on the app, the three criminals sit in different parts of the casino and play extremely aggressive hands (splitting 10s, hitting on 17s, etc.) and routinely go bust, so as to let their fourth friend win. This new skill-based app has allowed a group of criminals to gamble together in the casino and launder their money (for a relatively small fee) without them ever sitting at the same table or otherwise interacting within the casino. It is the modern day equivalent of partners in crime betting on both black and red in roulette. This offsetting bets scenario presents new challenges for casinos' anti-money laundering programs.

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