Part III: Business & Regulation · Gaming Regulation & Compliance

Layering

AML/CFT

The second stage of money laundering, involving the creation of complex layers of financial transactions designed to obscure the audit trail and sever the connection between the illicit funds and their criminal source. In casinos, layering may involve rapid chip purchases and redemptions, transfers between accounts, wire transfers to and from multiple jurisdictions, conversion between different financial instruments, and the use of nominees or intermediaries. Layering is the most complex stage and can be extremely difficult to trace without robust transaction monitoring systems.

One entry from the Casino Industry Glossary — 1,157 terms written for surveillance, compliance and operations professionals rather than for players. Definitions describe industry usage; where a term carries a regulatory meaning, verify against the instrument that governs your jurisdiction.