FATF Names VPN Use, Split Deposits as Laundering Indicators

International body FATF published a report titled "Risks of Gaming and Gambling," outlining a list of risk indicators for money laundering within the gambling sector. The report draws on survey responses from 80 jurisdictions across FATF's global network, along with written comments and case studies submitted by 29 jurisdictions.

Among player-level risk indicators, the report highlights repeated VPN use, multiple devices, and discrepancies between stated residence and detected location, as well as IP address location changes with each login. Other flagged behaviors include mismatches between account details and payment method information for deposits and withdrawals, multiple accounts registered under different names from the same IP address or device, and withdrawals shortly after deposits with minimal actual gameplay. Additional indicators include refusal to complete video identity verification, regular withdrawals kept just below verification thresholds, deposits kept just below regulatory reporting thresholds, betting on all possible outcomes of a single event, anomalies in peer-to-peer games where one player consistently loses to another, and bets placed by individuals connected to the sport they are wagering on, including referees, players, coaches, and club or federation staff.

At the operator level, the report flags excessive reliance on third-party suppliers and white label solutions, promoting products in jurisdictions where online gambling is prohibited, settling payments with suppliers and partners using virtual assets, and frequent changes to website URLs, company names, or brands. Additional operator-level indicators include economically unjustified contracts with software, marketing, or consulting providers, complex cross-border ownership structures obscuring beneficial owners, accepting player payments through accounts registered for unrelated business activities, sharp revenue or player growth without a corresponding increase in business scale, and licenses obtained followed by extended periods of no operational activity. FATF noted the list is not exhaustive, that no single indicator alone confirms money laundering, and that some indicators may instead reflect problematic gambling behavior rather than criminal intent.