Over recent years, I have been doing quite a bit of work with the e-gaming sector, and before that I did have a couple of “real” (as opposed to “virtual”) casino clients. But what nearly all of them, whether bricks or clicks, agreed on was that laundering through the gambling sector is both difficult and rare. As with all sectors, it is of course jolly difficult to find statistics to support or disprove that view, although I have always felt that an industry that is either heavily cash-based (for the brick casinos) or with anonymised users (for the click ones) must be very attractive to money launderers.
And so it is with a certain degree of relief (after all, no-one wants to peddle their services to a sector that doesn’t need them) that I read about the current investigation into possible money laundering through the Caesars Palace casino in Las Vegas. Caesars Entertainment Corporation has said in a filing with the SEC that it is under investigation by FinCEN (the American FIU) for alleged violations of the Bank Secrecy Act, and that a federal grand jury investigation is also being conducted. All very early days – FinCEN is still deciding “whether it is appropriate to assess a civil penalty and/or take additional enforcement action against Caesars Palace”, while Caesars’ own filing with the SEC says that “based on proceedings to date, [we are] currently unable to determine the probability of the outcome of these matters or the range of reasonably possible loss, if any” – but at the very least it demonstrates that rumours of the demise of the casino as a target for money laundering may well have been premature.