S W E N U M

AML - Anti-Money Laundering

01.

Overview

AML - Anti-Money Laundering in iGaming leverages AI and machine learning to detect, investigate, and report suspicious financial activities and money laundering schemes across gaming platforms. By analyzing transaction flows, player funding sources, withdrawal patterns, and network relationships, this solution enables operators to comply with FATF, FinCEN, and regional AML regulations while protecting their licenses and reputation from financial crime.

02.

What is it?

A comprehensive AML compliance and monitoring platform, it combines:

  • Supervised Machine Learning: Classification models for money laundering risk scoring using transaction history, player profiles, and known typologies
  • Unsupervised Learning: Anomaly detection, clustering, and network analysis to identify suspicious patterns and unknown laundering schemes
  • Transaction Monitoring: Real-time analysis of deposits, withdrawals, betting activity, and fund flows to detect structuring, layering, and integration
  • Sanctions Screening: Automated checking of player names, addresses, and beneficial owners against global watchlists (OFAC, EU, UN, etc.)
  • Know Your Customer (KYC): Enhanced due diligence for high-risk players, beneficial ownership verification, and source of funds validation
  • Network Analysis: Relationship mapping to identify organized criminal networks and money laundering conspiracies
  • Typology Recognition: Pattern matching for known AML schemes (structuring, nested betting, round-tripping, layer-cake funding)
  • Continuous Learning: Models adapt to evolving money laundering tactics and regulatory requirements
03.

Use cases

  • Suspicious transaction reporting (STR): Automated detection and filing of transactions meeting SAR/CTR thresholds
  • Structuring detection: Identify players breaking deposits/withdrawals into smaller transactions to avoid reporting requirements
  • Layering pattern detection: Flag complex betting sequences designed to obscure illicit fund origins
  • Integration monitoring: Detect unusual withdrawal patterns moving illicit funds out of gaming platforms
  • Sanctions compliance: Real-time screening against OFAC, EU, UN, and local watchlists for prohibited individuals and entities
  • High-risk player monitoring: Enhanced due diligence for PEPs, high-value players, and jurisdictions with elevated AML risk
  • Beneficial ownership verification: Identify ultimate beneficial owners and control structures of corporate accounts
  • Source of funds validation: Analyze player profiles, employment, and transaction patterns against declared funding sources
  • Cross-border transaction analysis: Monitor international fund flows and identify unusual geographic patterns
  • Regulatory reporting: Generate SARs, CTRs, and compliance documentation for gaming commissions and financial intelligence units
04.

Why needed?

iGaming operators face severe AML compliance pressures and risks:

  • Regulatory Mandate: FATF, FinCEN, EU AML5/6, and gaming commission regulations require robust, auditable AML controls
  • License Risk: AML violations result in license suspension, revocation, and operator shutdown
  • Financial Penalties: Fines reach billions of dollars; past enforcement actions against major operators demonstrate escalating consequences
  • Reputational Damage: Association with money laundering or financial crime destroys operator credibility and payment partnerships
  • Transaction Volume: Millions of daily transactions require automated monitoring; manual review is infeasible at scale
  • Sophisticated Typologies: Criminals employ evolving schemes tailored to gaming platforms; static rules become obsolete
  • Jurisdictional Complexity: Multi-licensed operators must comply with varying AML standards across 20+ jurisdictions
  • False Positive Cost: Excessive alerts overwhelm compliance teams; genuine SAR/CTRs are missed
05.

Why matters?

  • Regulatory Compliance: Meet FATF, FinCEN, EU, and gaming commission AML requirements for license maintenance
  • License Protection: Avoid suspension, revocation, or shutdown through demonstrated effective AML controls
  • Financial Stability: Prevent billion-dollar fines and enforcement actions that threaten operator viability
  • Reputational Protection: Maintain trust with payment processors, banks, and customers by preventing financial crime association
  • Operational Efficiency: Automated AML monitoring reduces manual review burden and enables risk-based due diligence allocation
  • Financial Crime Prevention: Prevent money laundering, terrorist financing, and organized crime use of gaming platforms
  • Competitive Advantage: Strong AML controls enable access to premium payment partners and regulated markets
  • SAR/CTR Accuracy: Properly filed suspicious activity reports support financial intelligence units in combating financial crime
06.

Latest advances in AML compliance and monitoring

AML compliance in iGaming leverages advanced techniques from financial services, law enforcement, and AI research:

  • Graph neural networks for financial crime network detection and relationship analysis
  • Explainable AI for transparent SAR/CTR justification and regulatory audit readiness
  • Real-time streaming ML for instantaneous transaction-level risk assessment
  • Natural language processing for KYC document analysis and beneficial owner identification
  • Predictive risk scoring for high-risk jurisdiction and PEP identification
  • Behavioral biometrics for login patterns and account activity anomalies
  • Federated learning for cross-operator intelligence sharing while maintaining data privacy
  • RegTech integration for streamlined regulatory reporting and compliance documentation
  • Sanctions list integration and continuous watchlist monitoring
  • Multi-modal risk assessment combining transaction, behavioral, and contextual signals

These advances enable proactive financial crime detection while meeting stringent regulatory standards and reducing false positive burden.

07.

Our solution: AML compliance platform

We deliver comprehensive, jurisdiction-specific AML solutions tailored to your operator profile and regulatory environment. Our approach:

  • Discovery: Audit your current AML controls, transaction monitoring, KYC processes, and compliance gaps against FATF, FinCEN, and gaming commission standards
  • Architecture Design: Design end-to-end AML pipelines covering sanctions screening, transaction monitoring, customer due diligence, and suspicious activity reporting
  • Technology Selection: Deploy advanced ML models, watchlist integration, rules engines, and case management systems optimized for your jurisdictions
  • Development & Validation: Build and validate AML risk scoring, typology detection, and SAR/CTR filing systems compliant with regulatory requirements
  • Deployment: Integrate AML controls into player onboarding, funding, betting, and withdrawal workflows with real-time decision APIs
  • Monitoring & Maintenance: Continuous AML monitoring, typology evolution tracking, watchlist updates, model retraining, and compliance documentation

Flexible Architecture and Deployment

  • Cloud Deployment (AWS, Azure, GCP):
  • Scalable infrastructure for high-volume transaction processing and real-time screening
  • Integration with managed compliance services and RegTech platforms
  • Automated regulatory reporting and audit trail generation
  • On-Premises Deployment:
  • Full control over sensitive customer data and AML investigation files
  • Compliance with strict data residency and sovereignty requirements
  • Air-gapped environments for restricted jurisdictions or government operators
  • Hybrid Deployment:
  • Real-time transaction screening on-premises with advanced analytics and reporting in the cloud
  • Meets data governance mandates while leveraging cloud scalability for model training
08.

Our solution: Implementation journey

Phase 1: Assessment and Compliance Strategy:

  • Conduct comprehensive audit of current AML controls, transaction monitoring, and KYC processes
  • Map your regulatory obligations across all licensed jurisdictions (FATF, FinCEN, EU AML5/6, gaming commissions)
  • Identify compliance gaps and prioritize remediation based on regulatory risk and license criticality
  • Design jurisdiction-specific AML architecture aligned with local requirements and best practices

Phase 2: Pilot Deployment:

  • Deploy AML screening and transaction monitoring on a subset of players or a single jurisdiction
  • Validate sanctions screening accuracy, transaction monitoring rule effectiveness, and false positive rates
  • Test SAR/CTR generation, documentation quality, and regulatory reporting workflows
  • Calibrate detection thresholds and rules based on pilot results and compliance team feedback

Phase 3: Production Integration:

  • Deploy AML controls across all player segments, jurisdictions, and transaction types
  • Integrate with player onboarding, KYC verification, funding, betting, and withdrawal systems
  • Establish SAR/CTR filing workflows with financial intelligence units and gaming commissions
  • Train compliance team, operations staff, and management on AML workflows and regulatory obligations

Phase 4: Continuous Monitoring and Optimization:

  • Monitor AML detection performance, false positive rates, and regulatory filing accuracy
  • Track emerging money laundering typologies and update detection models accordingly
  • Maintain watchlist currency and integrate new sanctions designations in real-time
  • Conduct quarterly compliance audits and prepare for regulatory examinations
  • Expand AML controls to new jurisdictions, products, and player segments as business grows
  • Participate in industry AML working groups and information sharing for financial crime intelligence

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