Michael Howard 8 Dec 20 6 min read

Responding to AML-related disruption in the entertainment industry.

“The game has changed” was a recent webinar series that examined the potential governance, operational, and regulatory impact that COVID-19 is causing within the entertainment industry around the world. With input from industry experts at various stages of pandemic-enforced lockdowns, speakers shared a range of insights regarding guest restrictions, stringent health and safety measures, and compliance pressures.

This article features combined insights by Richard Storey, Risk Solutions Sales Director at Refinitiv, Malcolm Rutherford, Executive VP of Strategic Operations at eConnect, Phil O'Connell, Group General Manager Regulatory Affairs and AML at SkyCity Casino, and Colin Dixon, Product Manager at Jade ThirdEye.

How has the pandemic impacted the AML programme at SkyCity Casino?

One of the biggest changes SkyCity Casino has noticed is the change in customer demographics. The closure of the border meant the casino moved to a solely domestic-focused business. Because of this, their AML programme became far narrower than ever. Managing risks associated with PEPs, customers from high-risk countries, and the movement of funds across international borders were each issues that were, and still are, practically no longer evident.

Further to this, the junket part of the business had also been temporarily halted too. With this downturn in activity, AUSTRAC used the opportunity to prepare a junket risk assessment report, which will provide further guidance to casino operators.

On the positive side, like AUSTRAC, this reduction in AML activity has given SkyCity the time to review their risk mitigation strategies and processes for managing the international customer segment. SkyCity already believe that risk assessments are fluid and evolving; they know disruptive events like the current pandemic are perfect for challenging the status quo. That’s why their compliance teams have been reviewing their practices and rules to make sure they’re fit for purpose.

How have New Zealand regulators responded to the change?

SkyCity’s AML regulator, the Department of Internal Affairs (DIA), have been very proactive and kept up their communication, guidance, and advice with their stakeholders throughout the pandemic. There has been no relenting from a compliance perspective, though there have been some changes in schedules due to lockdowns, such as their on-site inspections and desktop reviews.

How is technology augmenting entertainment businesses’ AML programmes through these times?

Customer due diligence (CDD) and needing to know more about customers is a key part of delivering compliant AML programmes. By using customer screening software and facial recognition software, there’s generally adequate servicing of this CDD for table games due to their face-to-face nature and high volumes of transactions. Slot machines, however, have historically been ignored due to the lower cash volumes. A focus on knowing the customers on slot machines, particularly for long-stayers, is increasingly becoming a focus, which is addressed by similar technology as per tables.

Automation is hugely beneficial for increasing various operational efficiencies. However, it does need to be monitored, and have checks and balances put in place to make sure all transactions that need to be reported are reported. For those considering augmenting their entertainment business with technology, be assured that the time saved through automation typically far outweighs the time spent monitoring.

The potential for facial recognition software to interact with transaction monitoring software is also exciting. Historically, transaction monitoring or customer screening has been facilitated using lists. Until now, there has been no facial or visual reference for transaction monitoring software to utilise. At the simplest level, facial recognition can associate an unknown player with various transactions throughout a venue. As the two technologies come together, plus with the addition of other customer datasets, the ability to remain unknown in a casino and gaming environment will become increasingly more difficult. Thanks to improvements to facial recognition, even the usage of masks, hats, and sunglasses aren’t enough to hide one’s identity – try as they may.

One final high-level benefit of technology is that, thanks to the ability to work from home, casino and gaming venues are able to overcome skilled worker shortages by hiring talent outside of their normal geographic talent pool. And since AML compliance is a growing industry, competition for top employees is only going to get stronger. So having the option of working remotely is a welcome consideration for hiring managers.


If you are considering augmenting your AML programme with technology to improve your compliance outcomes, talk to us. We can guide you through the decision-making process to help you protect your customers and community from the harms of and activity that money laundering fuels.

Talk to us about how to respond to AML-related disruption?