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Gambling on Crime at Casinos - FICA Obligations
Gambling on Crime at Casinos
FOR MOST patrons, casinos represent a pathway to winnings and financial freedom, for others, gambling establishments offer more sinister options.
There is little doubt the gambling industry is cash-flush. During 2018/19, the industry accumulated more than R30 billion in revenue. Casinos hit the jackpot, generating more than 60 percent of this total revenue i.e. more than R18.6 billion. This was followed by other betting modes that generated revenues of R7 billion, limited payout machines with R3.3 billion while bingo contributed R1.5 billion.
The gambling industry is largely a cash-based industry offering anonymity and a variety of ways to use cash. Casinos, in particular, are a lure and vulnerable to criminals looking for ways to launder and
Gaming For Africa legitimise their ill-gotten gains.
During a single visit to a casino, for example, a patron may undertake one or many cash or electronic transactions, at either the “buy in” stage, during play, or at the “cash out” stage. Casino value instruments are often used for money laundering by converting illicit funds from one form to another.
The exploitation of casinos typically arise in gambling modes where the products are not restricted in terms of limits on “cash out” and “buy in”. Other modes of gambling such as betting, limited payout machines and bingo are typically less vulnerable because of product restrictions and the way in which patrons access these modes.
Given that gambling operators are familiar with their industry, and their patrons’ behaviour and habits, these industry experts are best suited to identify when certain behaviour is suspicious or unusual.
Casinos must assess the risk of criminals abusing their products for money laundering and monitor patron activity to identify suspicious and unusual transactions and/or unlawful activity.
The Financial Intelligence Centre Act obliges casinos and all other business to report suspicious or unusual transactions or activity to the FIC. Section 29 of the FIC Act requires that all business (not only casinos) report to the FIC when they know or suspect money laundering i.e. when a transaction or activity “does not feel right”.
