As we have discussed in previous commentary regarding Macau casinos, the regulatory movement in Asia continues to strengthen with regards to money laundering controls, especially in the casino and gaming industry. 

While money laundering prevention initiatives are certainly a positive step, casino executives are incurring some added business risk as certain customer populations who value anonymity change their gaming habits. Key themes in mitigating this risk include:

  • Finding opportunities to address business risk within the compliance framework
  • Finding cost reduction opportunities within programs
  • Efficiency in leveraging technology and talent
  • Ensuring consistent customer experiences across different legal and regulatory jurisdictions

Now that Philippine casinos will undergo significant regulatory changes and pressures, their biggest challenge outside of technical program implementation will be developing a more robust culture of compliance including:

  • Establishing a system of internal controls and policies and procedures; 
  • Ensuring independent testing of AML compliance, of a scope and frequency that match the AML/CFT risks that are present;
  • Training casino personnel in the identification of unusual financial transactions or suspicious activities, recording and aggregation of currency transactions, all legal requirements and the casino’s compliance policies and procedures; and
  • Designating individuals responsible for assuring day-to-day AML compliance at all venues.