AML Compliance Case Study

SkyCity Casino $4.16M Fine

Lan’s Enterprise Limited Training Program

Presented by: Angela Ji Contact: aml@gmfinance.co.nz Emergency Hotline: +64 09-309-8808

Overview

  • Major AML/CFT breaches spanning 5 years (2018-2023)
  • Systemic failures in compliance program
  • $4.16M penalty imposed by regulators
  • Focus on international business customers
  • No direct evidence of money laundering found, but serious control gaps identified

Key Compliance Failures

Risk Assessment & Program Management

  • Inadequate AML/CFT compliance programme
  • Failures in risk assessment processes
  • Systemic non-compliance with core obligations

Customer Due Diligence

  • Poor monitoring of accounts and transactions
  • Insufficient enhanced due diligence
  • Failures to terminate high-risk relationships

Timeline

  • Violations occurred Feb 2018 - March 2023
  • DIA review conducted Sept 2022 - Dec 2023
  • Penalty finalized January 2025

Regulatory Context

“Casinos can be an attractive way for criminals to launder proceeds of crime. We cannot take the risk that criminals might choose New Zealand casinos as a way of cleaning their dirty money. Casinos must have robust processes in place to protect them from misuse.”

  • Department of Internal Affairs
  • International business customers identified as high-risk area
  • Part of broader regulatory focus on casino sector
  • Similar case: A$67M fine for SkyCity Adelaide

Impact & Response

Company Response

  • Accepted responsibility for failings
  • Issued public apology
  • Commitment to upgrade AML/CFT systems
  • 15 working days to pay civil penalty

Broader Business Impact

  • Reputational damage
  • Regulatory scrutiny increased
  • Potential license implications
  • Financial penalties in multiple jurisdictions

Key Lessons & Takeaways

  1. Robust compliance programs are essential
  2. High-risk customers require enhanced due diligence
  3. Regular program review and updates needed
  4. Documentation and monitoring crucial
  5. Swift action required for identified risks

Contact Information

Questions?

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