AML Compliance Case Study: SkyCity Casino $4.16M Fine
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.” ...