Part III: Business & Regulation · Gaming Regulation & Compliance

SMURFing

AML/CFT

A money laundering technique involving the use of multiple individuals (“smurfs”) to conduct numerous small cash transactions, each below the reporting threshold, to avoid triggering CTR obligations. The smurfs typically deposit or purchase chips at different times, locations, or casino properties, making it difficult to identify the aggregate nature of the transactions. SMURFing is a form of structuring and is a criminal offense. Effective transaction monitoring and information sharing across properties are essential to detect SMURFing operations.

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.