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Anti-Money Laundering(AML)

What is Anti-Money Laundering (AML)?


Synonyms:

Chinese TerminologyEnglish TerminologDescription
反洗钱Anti-Money Laundering(AML)The most commonly used and formal term in legal and compliance contexts.
反资金清洗Anti-Money LaunderingA less common alternative translation with the same meaning.
洗钱防制Anti-Money LaunderingA term widely used in Taiwan and Hong Kong, especially in the finance and gambling industries.

AML stands for Anti-Money Laundering in English, commonly translated in Chinese as “反洗钱”.
It is a set of financial compliance measures and regulatory systems designed to prevent illicit funds from being “cleaned” through legitimate channels. AML frameworks are widely applied in high-risk financial sectors such as banking, securities, cryptocurrency, and gambling.

Core objectives of Anti-Money Laundering:

  • Preventing funds generated from illegal activities such as drug trafficking, fraud, corruption, human trafficking, and terrorism from entering the financial system

  • Combating cross-border money laundering and international financial crime networks

  • Enhancing the transparency and stability of the global financial system



Origin and History of AML

  • 1989: The G7 established the Financial Action Task Force (FATF) in Paris to create the first set of international AML standards.

  • Post-2001: After the 9/11 attacks, FATF expanded its mandate to include Countering the Financing of Terrorism (CFT).

  • Since the 2000s: With the rise of online gambling, electronic payments, and virtual assets, AML regulations have expanded into these emerging sectors.


What Is Money Laundering? A Summary of the Three Stages

  1. Placement: Introducing illicit cash into legitimate channels (e.g., gambling platforms, banks, underground money exchanges)

  2. Layering: Obscuring the origin of funds through multiple transactions, cross-border transfers, and cryptocurrency mixing

  3. Integration: Converting laundered money into legal asset forms such as investments, real estate, or business funds



Key Institutions in AML Enforcement


International Organization

Name Role
FATF (Financial Action Task Force) The world's leading AML policy-making body; issues 40 AML Recommendations, monitors high-risk countries, and enforces the graylist/blacklist system.
Egmont Group A network of over 160 Financial Intelligence Units (FIUs) around the world, facilitating global AML information sharing.
World Bank / IMF Assist developing countries in drafting AML regulations and providing technical support.


Government Agencies (FIUs) by Country

Country Primary AML Authority
United States FinCEN (Financial Crimes Enforcement Network)
United Kingdom UKFIU (part of the National Crime Agency)
Malta FIAU (Financial Intelligence Analysis Unit) + MGA (for the gambling sector)
Canada FINTRAC (Financial Transactions and Reports Analysis Centre)
Singapore MAS (Monetary Authority of Singapore) + CAD (Commercial Affairs Department)
European Union EBA (European Banking Authority), responsible for unified AML policy-making


Specific AML Measures

Legal entities (e.g., gambling platforms, banks, exchanges) are required to implement the following AML procedures:

Category Description
KYC (Know Your Customer) Collect user identity information, address, and payment methods to ensure authenticity and legality
Suspicious Transaction Report (STR) Report any abnormal or suspicious transaction to the relevant authority
Sanctions List Screening Cross-check against sanctions lists (e.g., FATF, OFAC) to avoid transactions with high-risk individuals or entities
Transaction Monitoring System Use risk-control algorithms to detect fund irregularities and suspicious patterns
AML Staff Training Employees must undergo regular AML compliance and legal education
Third-Party Audit / Review Platforms must be reviewed by independent auditors to assess regulatory compliance and system integrity (e.g., GLI, iTech Labs)


Application of AML in the Gambling Industry

  • All licensed gambling platforms (e.g., those holding MGA, UKGC, CGA licenses) are required to establish comprehensive AML procedures.

  • Players must complete KYC during registration or their first withdrawal.

  • When players exhibit suspicious behavior such as high-stakes betting or frequent fund transfers, the platform must file a STR (Suspicious Transaction Report).

  • Platforms must submit an annual AML compliance report and are subject to random audits by regulatory authorities.



Risks of Non-Compliance with AML

Type of Consequence Description
Legal Liability The platform may face fines, license suspension, or criminal prosecution of key personnel
Business Impact Payment providers (e.g., Visa, Mastercard, Astropay) and suppliers may terminate partnerships
Brand Trust Breakdown Frozen player funds and withdrawal failures can severely damage brand reputation
International Pressure Countries listed on the FATF graylist or blacklist may face global financial sanctions and investment restrictions


How is AML Different from KYC?

Item AML KYC
Full Term Anti-Money Laundering Know Your Customer
Nature Macro-level framework (strategy + systems) Micro-level execution tool (identity verification)
Primary Objective Prevent financial crimes and terrorist financing Verify user identity and legitimacy
Level of Application Platform, national, and regulatory authorities Internal platform processes / user-level verification
Are They Related? KYC is a component of AML  


Summary

With increasing global compliance in the financial and gambling industries, AML is no longer just the responsibility of major banks—it has become a “basic rule of the game” for any business involving fund flows and user accounts. For gambling platforms, strict implementation of AML often directly determines whether they can obtain licenses, operate stably, and earn the trust of users and partners.