Why Casinos and Junket Tour Operators are exposed to financial crime risk
The global casino and gaming industry stands at the crossroads of high-value financial flows, international customers, complex service offerings and regulatory scrutiny. While this dynamic environment drives commercial opportunity, it also creates a fertile landscape for money laundering, terrorism and proliferation financing risks if not properly understood and managed.
For casinos and junket tour operators safeguarding the integrity of your business and demonstrating regulatory compliance requires more than fragmented policies – it requires a defensible, intelligence-driven enterprise-wide financial crime risk assessment framework.
Why Casinos and Junket Tour Operators are targeted by organised criminal networks
Casinos and Junket Tour Operators are inherently exposed to financial crime risk for several reasons:
- High Value, High Velocity Transactions: Gaming floors and junket operations typically handle large sums of cash and electronic transfers every day. These flows can be layered, structured and routed in ways that create ideal conditions for laundering illicit funds.
- International and Cross-Border Activity: Casinos and tour operators deal with global clientele including high-net-worth individuals, foreign visitors and VIPs. Cross-border movement of funds increases exposure to jurisdictional risk and sanctions complexity.
- Third-Party Introducers and Intermediaries: Junket tour operators, VIP hosts and travel partners often bring customers into casinos – creating multiple pathways for potential misuse if risk is not clearly identified and managed.
- Complex Customer Profiles: Clients may operate through shell companies, trusts or corporate vehicles – requiring deep understanding and mapping of beneficial ownership, source of funds and ongoing transaction behaviour.
These realities mean that Casinos and Junket Tour Operators can no longer rely on outdated, fragmented or spreadsheet-based financial crime risk assessments.
Introducing Arctic Intelligence’s ML/TF/PF Risk and Control Module for Casinos
Arctic Intelligence’s Casino Risk and Control Module provides a comprehensive and configurable foundation for conducting robust ML/TF/PF risk assessments tailored to this sector. This module helps you:
- Identify and Prioritise ML/TF/PF Risks: Using a sector-relevant risk taxonomy, the module guides you through identifying the highest-impact risk areas including customer segments, VIP programmes, cash operations, junket relationships and cross-border exposure.
- Assess Controls and Operational Effectiveness: Better than static checklists, the solution enables you to map controls to risks, test their design and evaluate their performance in practice. That means you can show, with data, that your controls are working as intended.
- Calculate Residual Risk Transparently: Residual risk is the real measure of your exposure. Arctic’s module automatically aggregates risk indicators and controls effectiveness to produce defensible residual risk ratings — providing a clear link to risk appetite and governance outcomes.
- Produce Audit-Ready Documentation: Regulators increasingly focus on the why and how of risk assessments. With built-in audit trails, version history and aggregated reporting.
Who does this module apply to?
The money laundering, terrorism and proliferation financing risk and control module contains a library of risks, controls and control tests designed specifically for different types of Casinos and Junket Tour Operators:
| Casino Operators | Junket Tour Operators |
| Gaming Resorts | Junket Tour Promoters |
| Casino Tourism Services | Private Gaming Operators |
| Integrated Resort Operators |
What does this module contain?
Enterprise-wide ML/TF/PF risk assessment, covering the following risk groups:
- Environmental Risk – covering exposure to internal and external risk indicators
- Customer Risk – covering customer base profile, customer location risk, legal form risk, industry / occupation risk, PEP risk and customer activity risk.
- Industry Red Flag Risk – covering ML/TF/PF red flags associated with Casinos and Junket Tour Operators.
- Product and Services Risk – covering the services provided by Casinos and Junket Tour Operators that are subject to AML/CTF laws and the inherent risk characteristics of each of these.
- Channel Risk – covering face-to-face and non-face-to-face customer onboarding and transaction channels.
- Transaction Risk – covering higher risk transaction types.
- Country Risk – covering higher risk country risk exposures based on the residency, nationality or citizenship (Individuals) and country of registration, incorporation, domicile or operations (Entities).
Also included is a comprehensive library of suggested controls and control tests relevant to casinos to support the design and operational effectiveness testing of controls.
Firms can deploy the content module out-of-the-box or tailor it to their methodology, eliminating the need to start from scratch while maintaining full ownership of their risk model.
The module also includes a comprehensive library of suggested casino controls and control tests to support design and operational effectiveness testing.
From regulatory obligation to strategic risk insight
The Arctic Intelligence module includes:
- Pre-built risk libraries tailored to casino and junket business models
- Casino-specific risk indicators for cash handling, VIP programs, junket relationships and cross-border play
- Scalable risk taxonomies that adapt to single venues or multi-jurisdiction operations
Best of all, this content is fully tailorable. Whether you are a single property operator or a multi-national gaming group, you can configure the model to reflect your risk profile and compliance obligations.
Casinos and Junket Tour Operators must demonstrate that their compliance frameworks are intelligent, adaptive and defensible. Arctic Intelligence’s ML/TF/PF Risk and Control Module transforms risk assessment from a compliance obligation into a strategic asset – one that strengthens controls, enhances decision-making and reduces regulatory risk.
Get started with Arctic Intelligence
Whether you are establishing your first enterprise-wide ML/TF/PF risk assessment or upgrading a legacy spreadsheet-based program, Arctic Intelligence’s Casino Risk and Control Module is a scalable, defendable and configurable solution that meets the needs of modern compliance teams.
Book a demo or contact us to explore how our platform can help your Casino strengthen compliance, mitigate financial crime risk and build a risk program that stands up to regulatory scrutiny.
Or visit our website to learn more.
