As part of the UCIF programme, a training session was held on 5 December for representatives of land-based and online casinos, focusing on compliance with regulatory requirements for the prevention of money laundering and terrorist financing.
The Strengthening Ukraine’s Capacity to Counter Illicit Finance (UCIF) aims to lay the foundations for a long-term, systemic reform of Ukraine’s financial ecosystem. The project brings together government institutions, regulators, law enforcement agencies, financial institutions, and international partners to reduce the scale of the shadow economy, increase transparency in the financial sector, and combat money laundering. It is implemented by DAI Global with the support of the UK Foreign, Commonwealth & Development Office (FCDO).
This training was organised by the Center for Financial Integrity in partnership with the Centre for Finance and Security (CFS) at RUSI. The event was moderated by Olivia Allison — compliance and sanctions expert, Associate Fellow at RUSI, Advisory Board Member at the Center for Financial Integrity, and former Partner at KPMG.
Gambling operators are considered high-risk due to the nature of their activities and the ways transactions are conducted. Players can use anonymous payment methods, including credit and debit cards, prepaid cards, cryptocurrencies, and other virtual assets, to fund their accounts. This anonymity allows funds to be concealed from regulators and enables agreed-upon losses and wins as a means of transferring money between players.
Online gambling has several specific characteristics that make detecting suspicious activity more difficult. Platforms process large volumes of deposits, withdrawals, and internal transfers almost instantly, allowing criminals to “mask” illicit transactions among normal gaming activity.
Compared to physical casinos, online platforms in some jurisdictions are subject to weaker oversight and less effective anti-money laundering (AML) controls. Furthermore, funds can move across borders easily, especially if the operator is based in a jurisdiction with lenient or inconsistent rules, allowing criminals to layer money through different regulatory systems.
Operators should pay particular attention to certain patterns of player behaviour. The higher the risk posed by a client, the more thorough the due diligence should be. Suspicious indicators include clients attempting to open multiple accounts with slight variations in personal information, large deposits on new accounts, frequent top-ups over a short period, the use of multiple cards or anonymous payment methods, activity from multiple IP addresses and countries, and minimal gaming activity despite significant deposits.
Modern technologies have significantly increased the complexity of controlling the gambling sector. In particular, the growth of cross-border online gambling creates opportunities for fraud, as criminals can exploit regulatory differences between countries, varying AML standards, and weak supervision in certain jurisdictions.
A growing concern is the use of synthetic identities, where fraudsters create fully or partially fictitious accounts by combining real and fake information. These accounts are extremely difficult to detect using traditional control systems. They can be used to open bank and payment accounts, obtain loans, or carry out other illegal financial operations. Synthetic identities are becoming increasingly realistic through technologies such as artificial intelligence and deepfake, making fraud detection even more challenging.
Problems in AML/CTF (counter-terrorist financing) often arise not from systemic shortcomings but from human error and inadequate oversight. Examples include irregular Customer Due Diligence (CDD) checks, insufficiently detailed procedures, excessive employee discretion, failure to retain evidence of conducted checks, and ignoring suspicious cases. Effective control requires clear, standardised procedures, regular audits, and strict adherence to established thresholds and rules to minimise the risk of fraud and money laundering.