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The Financial Action Task Force (FATF) has published a report setting out red-flag risk indicators across the gaming and gambling sector. The indicators cover money laundering, terrorist financing and proliferation financing. 

FATF released the report – Risks of Gaming and Gambling – on Wednesday. It updates the body’s 2009 analysis of the casino sector. In addition, it draws on questionnaire responses from 80 jurisdictions and written comments from a further 29, alongside industry consultation.

The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk. 

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“One fact of financial life should never be forgotten. Wall Street–to use the term in its figurative sense–would like its customers to make money, but what truly causes its denizens’ juices to flow is feverish activity. At such times, whatever foolishness can be marketed will be vigorously marketed–not by everyone but always by someone,” Buffett warned.

Buffett was not always entirely anti-gambling. Before commercial sports betting expanded across the United States, he regularly offered $1 million annually to any Berkshire Hathaway employee who submitted a perfect NCAA March Madness men’s basketball bracket.

To date, no individual has ever recorded a verified perfect NCAA tournament bracket.

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Notably, the Spectrum report does acknowledge that Evolution did not knowingly allow games in prohibited territories, however, it has also flagged a number of compliance issues, which resulted in its games being provided in markets where online gambling is, or has been, prohibited.

Here are some of the dossier’s key findings, some of which raise questions around Evolution’s compliance operations during the period assessed.

Within the initial pages of its lengthy August 2021 report, Spectrum Gaming explains it carried out an extensive technical, operational and compliance review of Evolution’s “business practices, public record database research and an assessment of the company’s anti-money laundering compliance procedures and processes, as they related to the allegations contained in the ‘anonymous report'”.