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Navigating the complex world of AML compliance in online casinos 

July 11, 2025
Last update: July 11, 2025
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Navigating the complex world of AML compliance in online casinos 

The online gambling industry is booming, but behind the glitz and glamour lies a complex web of regulations, particularly concerning Anti-Money Laundering (AML) compliance. This blog post delves into the intricacies of AML in online casinos, based on an insightful interview with Owen Baldacchino, Deputy Money Laundering Reporting Officer and online casino compliance expert with 10 years of experience in the industry.

The ever-evolving landscape of AML compliance 

Owen begins by highlighting the shifting regulatory landscape, particularly in jurisdictions like Curaçao (CORACO), which were once considered easier to enter due to less stringent regulations compared to Europe. However, this is changing. He emphasizes the crucial role of AML compliance in online casinos, mirroring the stringent measures seen in banks and financial institutions. This involves robust reporting, thorough risk assessments (both business and player-specific), and comprehensive staff training.  

The challenges of AML in the digital realm 

One of the biggest challenges in online casinos is the lack of face-to-face interaction. Owen explains the processes involved, including rigorous ID verification and sanction screening to prevent sanctioned individuals from participating. He stresses the importance of training and mentoring future AML officers, highlighting the significant reporting requirements to both regulators and management, as well as the constant evaluation of payment products and associated risks.

Risk sssessment: a multi-faceted approach 

The interview delves into the specifics of player risk assessment, focusing on four key areas: customer details (including source of funds), age, geographic location, and payment methods. Discrepancies between deposited funds and a player’s apparent wealth trigger further investigation. Owen explains why debit cards are generally safer than cash-based voucher methods due to AML concerns, emphasizing that the legality of cash itself isn’t the issue; rather, it’s the potential for concealing the origin of funds.  

Investigative techniques and the importance of discretion 

The process of investigating suspicious activity is carefully explained. Owen details how skilled AML analysts conduct thorough searches using internal databases and external verification tools without alerting players – a crucial aspect to avoid the criminal offense of “tipping off.” He highlights the rewarding aspect of this work, noting that AML reviews can contribute to larger crime investigations, including combating human trafficking and modern slavery.  

The discussion then shifts to the complexities of obtaining and maintaining licenses in various jurisdictions. Owen addresses the differences between European AML regulations and those in less regulated markets, such as CORACO. He explains the challenges of operating in “gray markets” where local online regulation is either absent or only covers specific products. He compares the regulatory approaches of different jurisdictions, including the UK, Isle of Man, Gibraltar, Malta, and Curaçao, emphasizing the importance of local presence and regulatory expertise.  

The Malta Gaming Authority (MGA) 

Owen provides a detailed overview of the MGA, highlighting its maturity and experience. He discusses the requirements for obtaining an MGA license, including the stringent vetting process for the Money Laundering Reporting Officer (MLRO) and the need for a physical presence in Malta. He also addresses the rising costs associated with obtaining an MGA license.  

AI and Crypto in AML Compliance 

The interview explores the potential of emerging technologies in AML compliance. While acknowledging the risks associated with cryptocurrency’s use in illicit activities, Owen suggests that its potential for increased transparency could streamline KYC/AML processes. He also discusses the role of AI and machine learning, emphasizing that AI should act as an advisory tool, assisting human analysts rather than replacing them entirely. He cautions against blind trust in AI and stresses the importance of careful consideration of data sources and training data.

Striking a balance 

The conversation concludes with a discussion on the future direction of market regulation. Owen expresses concerns about overly burdensome regulations, emphasizing the need for a practical approach that balances responsible gambling initiatives with the need for innovation and a thriving industry. He highlights the importance of operator involvement in shaping regulations and the need for regulators to understand the realities of human psychology in gambling behavior.

Key takeaways: 

  • AML compliance is paramount in the online gambling industry. 
  • Risk assessment is a multi-faceted process involving various factors. 
  • Obtaining and maintaining licenses requires significant investment and expertise. 
  • Emerging technologies like AI and crypto have the potential to improve AML processes, but careful consideration is needed. 
  • A balanced regulatory approach is crucial for the long-term health of the industry. 

This blog post provides a comprehensive overview of the complexities of AML compliance in the online casino industry. It’s clear that navigating this landscape requires a deep understanding of regulations, technology, and human behavior. The insights shared by Owen Baldacchino offer valuable guidance for both established operators and those entering this dynamic market. 

This article is based on an episode of the CEOpen mic podcast. For the full conversation and more insights, tune in to CEOpen mic on YouTube and Spotify – don’t forget to subscribe so you never miss an episode! 

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