Anti-Money Laundering (AML)

Reviewed by Royal Reels | Australia’s leading casino review site

At Royal Reels, we rigorously evaluate casino operators’ policies to ensure they meet—and exceed—international standards for preventing financial crime. After careful analysis of numerous AML frameworks, we believe the following components represent the gold standard of an AML policy. Below is our recommended AML guide, organized into clear sections for easy benchmarking.

1. Overview

To comply with applicable laws, regulations, and global best practices, a robust AML policy must include:

  • Risk Management & Classification

  • Customer Due Diligence (CDD) & Know Your Customer (KYC)

  • Appointment of an MLRO

  • Ongoing Monitoring & Reporting

  • Recordkeeping

  • Staff Due Diligence

2. Risk Management & Risk Classification

A risk-based approach allows a casino to focus enhanced controls where they’re needed most.

2.1. Low-Risk Customers

  • All newly registered players begin as Low Risk.

  • Standard due diligence applies: basic KYC document collection and routine activity monitoring.

2.2. High-Risk Customers

  • Elevated to High Risk if automated alerts or suspicious patterns emerge (e.g. unusually large deposits, rapid large-stake play, multiple login locations).

  • Subject to Enhanced Due Diligence (EDD), including deeper identity verification and source-of-fund checks.

 

3. Customer Due Diligence (CDD) & Know Your Customer (KYC)

Strong CDD/KYC processes are vital to safeguarding both the operator and the wider financial system.

3.1. KYC Information Collection
Before any wagering:

  • Full name, date of birth, and proof of age (18+).

  • Valid photo ID (passport or driver’s license) and proof of address (utility bill or bank statement).

  • Verified email, residential address, and payment details.

  • One account per individual, family, or shared environment.

3.2. Geolocation & Jurisdiction Checks

  • IP-based geolocation ensures players are within permitted regions (e.g. Australia).

  • Deny registration from restricted or high-risk jurisdictions.

3.3. Account Verification Workflow

  1. Automatic review of submitted documents.

  2. Request additional evidence if discrepancies arise.

  3. Hold or terminate the account if false or misleading information is uncovered.

 

4. Due Diligence Levels

4.1. Standard Due Diligence (SDD)

  • Verify identity with primary ID and proof of address.

  • Can occur at onboarding or upon withdrawal requests.

  • Phone verification may be used to confirm key details.

4.2. Enhanced Due Diligence (EDD)
Triggered for High-Risk customers, including:

  • Nationals of non-reputable jurisdictions or politically exposed persons (PEPs).

  • Evidence of collusion or multiple accounts.

  • Large or unusual transaction patterns.

Required EDD steps:

  • Photo “selfie” holding ID.

  • Recent bank statements showing initial deposit.

  • Declaration of source of wealth.

  • Utility bill no older than three months.

 

5. Money Laundering Reporting Officer (MLRO)

A designated MLRO is the lynchpin of any AML program.

Responsibilities:

  • Oversee KYC reviews and transaction monitoring.

  • Maintain the register of all account holders.

  • Provide mandatory AML training to staff.

  • Serve as the contact point for regulators and law enforcement.

  • Escalate and report suspicious transactions to the Financial Intelligence Unit (FIU).

 

6. Monitoring of Account Holder Activities

6.1. Automated Surveillance

  • Real-time transaction monitoring generates alerts for review.

  • AI-powered tools flag irregular patterns (e.g., zero-risk bets, multiple accounts).

6.2. Manual Review

  • Designated compliance personnel investigate alerts.

  • Actions may include temporary suspension, document requests, or account closure.

6.3. Specific Triggers

  • Multiple Accounts: One player, one account rule—same IP, address, or device.

  • Unusual Activity: Large single deposits without betting activity, rapid win/loss cycles.

  • Geolocation Breaches: Login attempts from prohibited jurisdictions.

 

7. Withdrawal & Payout Controls

To prevent layering and rapid cash-outs:

  1. Verify KYC before any withdrawal.

  2. Only pay to verified bank or e-wallet accounts in the player’s name.

  3. Suspend or cancel requests if suspicious activity is detected; request further documentation.

  4. Report any unresolved or suspicious transactions to the MLRO for FIU submission.

 

8. Cryptocurrency Transactions

Given the pseudonymous nature of crypto, tighter controls apply:

  • First deposit must be verified on-chain to the player’s wallet.

  • All subsequent transactions (deposits, wagers, withdrawals) use the same currency and wallet address.

  • Display real-time exchange rates on the homepage.

  • Advise players that crypto values fluctuate and the operator does not facilitate fiat-crypto exchanges.

  • Maintain solvency proofs for all on-site crypto balances.

 

9. Security & Periodic Reviews

  • Engage third-party verification services for ID, address, and payment checks.

  • Conduct periodic audits of the AML program—at least annually, or when regulations change.

  • Restrict account access and withdrawals during reviews.

 

10. Reporting of Unusual Transactions

  • The MLRO evaluates flagged transactions and decides on FIU reporting.

  • Maintain an internal log of all suspicious transaction evaluations, including documented justifications for non-reporting.

  • File Suspicious Transaction Reports (STRs) within jurisdictional timeframes (e.g., Curaçao FIU).

 

11. Recordkeeping

  • Retain KYC documents, transaction logs, and correspondence for a minimum of five years post-relationship.

  • Ensure records are accurate, tamper-proof, and retrievable for investigators.

 

12. Staff Due Diligence

  • All new hires submit a CV, references, and proof of certifications.

  • HR conducts background checks and qualifications verification.

  • Ongoing training programs keep staff up to date on AML obligations.

 

Royal Reels’ Verdict

As an independent casino review authority, we affirm that casinos adopting the above AML framework demonstrate the highest commitment to regulatory compliance, player protection, and global best practices. Operators who implement these procedures not only reduce financial crime risks but also foster trust among their Australian player base—especially fans of The Pokies, Instant Deposits, and Pay ID services.

“At Royal Reels, we judge a casino by the strength of its policies. This AML guide sets the benchmark.”