A fast withdrawal casino might refuse to cash you out if it has reasons to believe that you are gambling with dirty money. Under such circumstances, an attempt to deposit, gamble or withdraw might be perceived as a suspicious activity.
This article lists 10 hypothetical scenarios where UK casinos with fast withdrawals might suspect a player of money laundering as per the UK Gambling Commission. It's important to note that this list is not exhaustive and there may be other similar or unique scenarios that could trigger similar concerns.
Overall, the ground for suspicion can be summarised into the following:
- Placing large bets
- Gambling beyond your means
- Placing safe bets
- Winning big more often than not
- Winning every bet
- Unproportionate earning-to-spending ratio
- Accepting heavy losses regularly
- Depositing and withdrawing without gambling
As a player, you might recognize that you’re already gambling in a way that is grounds for a casino’s suspicion and you’d probably be right. Casinos regulated by the UKGC do keep a close eye on their players. However, as long as you’re innocent, you have nothing to fear.
Scenario 1: Unemployment, High Stakes and Criminal Ties
Example: John was recently released from prison after serving a sentence for drug dealing. He has been unemployed since his release but has been making large deposits and placing high-stakes bets at a certain UKGC-licensed fast withdrawal casino.
Now, the casino's security team has noticed that John's deposits are coming in large amounts, and he is making frequent withdrawals, sometimes several times a day.
Additionally, they have somehow received reports from multiple sources that John was seen conducting suspicious activities in his neighbourhood. This will lead them to suspect that he may be involved in drug dealing again.
The casino would then become increasingly suspicious of John's activities and conduct further investigation. His betting patterns and financial transactions would be stringently reviewed.
These patterns, combined with the reports of suspicious activities would surely raise alarm bells, compelling the casino to refuse any request for a withdrawal. This decision would be based on the suspicion that he was staking the proceeds of crime – possibly from drug dealing – to fund his lavish gambling lifestyle.
The casino would now need to see John’s source of funds and would ask for his bank statement and payslips. But John being unemployed would have a hard time proving his income of such big money.
The casino would then further the investigation to find out if the money he staked was earned from other sources such as house rental, sale of assets, inheritance, or winnings from other casinos. If he fails to provide evidence, he would eventually be reported as per the UKGC’s guidelines.
Scenario 2: High Stakes Gambling Beyond One’s Means
Example: Peter is a regular visitor at a certain fast withdrawal casino in the UK, and he usually bets around £100 per session. One fine day, he logs into the casino and starts betting thousands of pounds, which is way out of line with his typical gambling behaviour.
This sudden increase in his betting activity raises suspicions among the casino staff that he may be spending beyond his means or using illegally obtained funds. When the staff investigates further, they discover that Peter lives in a cheap housing area and has no visible source of income that could explain his sudden ability to bet high stakes.
This information further supports their suspicions that Peter may be using illegally obtained funds to place his bets. As a result, they may decide to report their concerns to the relevant authorities for further investigation.
This example illustrates how high-stakes betting that is not typical of a customer's usual spending habits can be seen as a red flag in a UKGC-licensed casino, particularly when there are additional factors that suggest the source of funds may be illicit.
It's important to note that the UKGC has not mentioned any specific amount that can trigger such a suspicion. It depends on the circumstances and what is known or suspected about you as a customer.
If the casino staff has any doubts about the source of your funds, they may ask for additional information to verify your identity and financial status.
Scenario 3: High Stakes and Minimum Loss With Nearly Guaranteed Returns
Example: Roy usually plays games with low odds of winning, such as slots and scratch cards with a £10 stake. But, one day, he suddenly starts placing high-value bets on a low-risk game such as blackjack or baccarat, which he has never played before.
Into the bargain, he happens to win most of his bets and his account balance jumps from £500 to £5,000 in a short time. The fast withdrawal casino may then flag this as suspicious activity and investigate further to determine if Roy is laundering money.
A similar suspicion of money laundering would arise if Roy bets on both red and black in roulette (which puts him at a high 97.3% chance of winning a game round) and consistently wins with a high stake. While he wouldn’t make a profit, he would wager a lot money.
In such cases, the casino would think that Roy might be trying to create a paper trail for the source of his ill-gotten gains to disguise the funds while minimizing the losses. Of course, this is not a definitive proof of money laundering.
But, it surely is a flag red enough to draw the attention of the fast withdrawal casino, which will then demand a further and thorough investigation to determine whether the suspicious activity is really taking place.
Scenario 4: Quick Deposits and Quick Withdrawals Without Gambling
Example: Bobby deposited £20,000 into his gaming account at a licensed fast payout casino. But, instead of playing with the funds, he left the money untouched for a whole month.
After that, he quickly withdrew the entire amount without engaging in any significant gambling activity by taking advantage of the UKGC’s rule that a player can cash out his entire funds in one go without the casino denying it.
This behaviour may ring all the alarm bells for the fast payout casino and cause it to suspect that Bobby is attempting to launder money through their platform. As a result, the casino may decline his cash-out request and report his activity to the relevant authorities.
It's essential to note that this type of behaviour is taken seriously by UKGC-licensed casinos, and it's crucial to avoid it to prevent legal repercussions. Normally, it is also necessary to wager your initial deposit at least once before you can cash it out.
Scenario 5: High-Stakes Gambling With an Appetite for Losses
Example: Max is a frequenter at a UKGC-licensed quick-paying casino. He regularly gambles large amounts of money and has a stomach for heavy losses. Even if he loses his entire stake, he seems unfazed and simply moves on to the next bet.
While this behaviour could indicate that Max is a wealthy player who can afford to take large risks or is suffering from gambling addiction, it's also possible that the funds he is staking were obtained through illegal means.
If this be the case, he might be willing to ‘lose’ his money to the casino as a way of masking its illicit origin and making any winnings appear legitimate.
The casino staff members would eventually take notice of Max’s big stakes and his high tolerance for losses. Subsequently, they would ask for the source of his funds. If Max cannot furnish a satisfactory explanation, the casino would have the legal obligation to report him.
As part of the investigation, the authorities would then review his financial records to ascertain if he has any legitimate source of income to support his gambling habit. If they find any evidence against it, Max may be charged with money laundering.
Scenario 6: Increased Average Spending Over a Short Window
Example: David has been a regular at a quick withdrawal casino for the past six months. During this time, he typically spends £100 per session on average. However, in the last month, his spending has increased significantly, with him now spending £5,000 per session on average.
Upon closer inspection, the casino staff notices that David has been splitting these larger deposits into multiple smaller transactions, perhaps to avoid detection.
This sudden increase in spending, coupled with the unusual transactional behaviour, raises suspicion that David might be laundering money through the casino using the ‘layering’ technique.
It involves the placement of large amounts of cash into a casino account through a series of transactions. The funds are then used to gamble and eventually cashed out at a later time to make them appear like legitimate winnings.
By monitoring David’s spending pattern, the quick withdrawal casino identifies his increased spending as a suspicious activity. To further investigate, they would look into his source of funds and check for links to any criminal activity as well. If their suspicions are confirmed, they would report the same.
Scenario 7: Out-Of-Kilter Annual Spending
Example: Finn frequently visits a UKGC-licensed online casino that pays out quickly. He deposits small amounts each time, usually around £50-£100.
However, over the course of a year, his total spending at the casino adds up to £50,000, which is significantly higher than what one would expect based on his individual visits. It could be an indicator that Finn has somehow managed to launder money through the casino.
By spending small amounts frequently, he could be trying to avoid suspicion and scrutiny from the authorities while converting illegal funds into legitimate winnings.
Unless Finn can explain the source of his out-of-kilter aggregate annual spending, the fast withdrawal casino would have to report him.
Scenario 8: Gambling Putting Casinos at Commercial Risk
Example: James has been a regular player at a fast paying online casino for a few months and has been playing with moderate bets. However, suddenly, he starts placing extremely large bets so frequently that it puts the casino at significant commercial risk. This can happen in two ways.
James has no prior history of high spending, and his sudden change in behaviour is perceived as potentially suspicious as it indicates that he might be trying to launder money through the casino.
Should this be the case, the fast paying casino could unknowingly facilitate illegal activity, which could lead to reputational damage, financial penalties, and even the loss of its license from the UKGC.
Again, if James is withdrawing large sums of money after winning consistently, the casino could potentially face liquidity issues if they do not have enough funds to cover his winnings. This could result in a loss of confidence from other customers and investors and ultimately affect the business’s bottom line.
To mitigate these risks, the fast paying casino must closely monitor James' activity and take appropriate measures to maintain their financial stability. This includes reporting suspicious activity and taking steps to prevent the suspected crime.
In this example, James's high spending alone is not necessarily suspicious, but when combined with other unusual behaviour and patterns that might lead the casino to significant losses, it becomes a red flag for the casino.
Scenario 9: Gambling on Behalf of a Criminal
Example: A UKGC casino with fast payouts becomes suspicious of Henry, a grandfather with no prior gambling history, who has been placing weekly bets of approximately £100.
The casino's security team looks into his source of funds (for instance, a bank statement) and discovers that Henry has been placing the bets with money sent by his grandson Rob, who is a known criminal. In this case, Henry is technically betting on behalf of Rob.
Upon reporting and further investigation, it is revealed that the money used for the bets is the proceeds of Rob's criminal activity. The casino would then have to immediately terminate Henry's account.
Scenario 10: Using Unverified and Suspicious Banking Methods
Example: Ben is a criminal who wants to ‘clean’ his illicit funds. He purchases a Paysafe card with the cash he illegally acquired. He then plans to use the card to directly deposit money into a UKGC-licensed quick payout casino or fund an e-wallet account and use it for the same.
Ben creates a new player account, puts in the money, and places a single roulette bet with the entire amount of his deposit. In general, this would give him back 97% of his money over time. But what he doesn’t realise is that this behaviour may be flagged as suspicious by the casino.
Banking methods like Paysafe can be easily used to eliminate traces of dirty money. The casino wouldn’t know for sure if Ben’s funds were illegally obtained. But due to his unusual betting activity, suspicion is enough to prompt them to freeze his account and file a report.
Is ‘Suspicion’ the Same as ‘Knowledge’?
As defined by the UKGC in the context of money laundering in casinos, ‘knowledge’ means actually knowing that someone is doing something illegal. ‘Suspicion’ means having a feeling or thinking that something is not right and there is a possibility that illegal activity is taking place.
In the context of a fast paying online casino, if operators have knowledge or suspicion that someone is involved in money laundering, they are required by law to report it. To report suspicious activity, the knowledge or suspicion must come to the casino operator during the course of their business or through a disclosure under the law.
It's not necessary to have evidence of money laundering to report the suspicion. Suspicion doesn't need to be based on clear or firmly grounded facts, but it can't just be a vague feeling either.
If something seems unusual or doesn't make sense, and it's investigated further, that can be considered suspicious. This can be done by checking the source of a player’s funds, which helps in detecting not just problem gambling behaviour, but also suspicious gambling activities.
Note that sometimes, a transaction that seems unusual may not be suspicious necessarily. Some players may have a different gambling pattern for valid reasons, and even regular players may have unusual transactions from time to time.
However, it's important to investigate further to determine if it is suspicious. If suspicions arise later, the activity must be reported. Nonetheless, unusual gambling patterns should receive attention, but they don't always lead to suspicion of money laundering.
The person in charge at a fast withdrawal casino must consider all the circumstances, for which he would need to ask more questions, especially regarding the whereabouts of the funds staked in the suspicious activity.
Still and all, it's not necessary to know the exact nature of any criminal offence or wait for a player’s conviction to suspect money laundering.
What Should a Fast Withdrawal Online Casino Do if it Detects Suspicious Activity?
Under the Proceeds of Crime Act 2002, if a fast withdrawal online casino is aware of or suspects that you are involved in money laundering or terrorist financing, they must report it to the National Crime Agency (NCA) by means of a Suspicious Activity Report (SAR). After that, they must provide the Gambling Commission with the NCA unique reference number.
The NCA accepts SARs in the following ways:
- SAR Online
- Paper-based reporting
- Encrypted bulk data exchange
SAR Online is a web-based reporting system for small and medium-sized casino businesses. It allows the electronic submission of SARs through the NCA SAR Online System as well as facilitates automatic acknowledgement of receipt, 24/7 reporting, and faster access to information by investigators.
Paper-based reporting, on the other hand, is done using the NCA's Suspicious Activity Report Form, which should be posted to the UKFIU. The third option – encrypted bulk data exchange is for high-volume reporters with over 10,000 reports per month.
Please note that the NCA prefers relevant information about the suspected player, transaction, or activity to be included in each SAR.
What Happens If the Casino Fails to Report?
If a fast withdrawal casino fails to report any suspicious activity when they should have, they could be charged with a crime.
To defend themselves, the operator would need to show that they took reasonable steps to investigate and verify the situation. A court will ultimately decide if they failed to report when they should have.
How Do the Grounds for Suspicion Affect the Average Joe?
Suspicion grounds normally don’t affect the average Joe as long as this person is innocent. Of course, if you play at a fast withdrawal casino and make large deposits, high-stakes bets or frequent withdrawals, you may be flagged for suspicious activities, despite your innocence.
However, the worst thing that would happen is that the casino will ask you to provide the source of your funds and ask for bank statements and payslips to verify the same. While this might bother you, it is not a unique occurrence for suspicious activities.
Regardless of the exhibited gambling behaviour, a UKGC-licensed casino will always investigate a player’s source of funds at some point. No player is immune to this scrutiny. If you fail to provide evidence of your funds, you may face refusal of withdrawals or even be reported, regardless of your innocence.
This, of course, will have an impact on your gambling experience. But the rules are the same for everybody. If you’re innocent, you’ll get through it; if not, you can kiss your money goodbye.
