The Critical Importance of Anti-Money Laundering Programs in the Hospitality Industry

The hospitality industry is not immune to the pervasive threats of money laundering and terrorism financing. It is so important to have effective anti-money laundering (AML) and counter-terrorism financing (CTF) program in place. Equally important is the training of staff to recognise and report suspicious activities.

A Real-World Example of Suspicious Activity

Earlier this year, a male patron at a club displayed behaviour that caught the attention of a vigilant gaming attendant. The man spent minimal time at a gaming machine before heading directly to the cash redemption terminal (CRT). The attendant’s suspicion led to the club’s compliance officer reviewing the CCTV footage.

Uncovering Suspicious Behaviour

The review revealed a clear pattern of suspicious activity. The individual approached a gaming machine, inserted $776, and immediately cancelled the credit, obtaining a ticket from the machine. He then proceeded to the CRT to cash in the ticket. Notably, this individual was a member of the club.

The Power of Awareness and Reporting

Thanks to the staff member’s awareness, evidence was gathered, and a Suspicious Matter Report (SMR) was submitted to the relevant authorities. This incident is a reminder of the importance of vigilant staff and effective AML/CTF programs.

The Moral of the Story: Money Laundering is Real

This example provides a stark reality check for those who might think money laundering is a non-issue in the hospitality sector. Money laundering is not only real but is a significant risk that requires constant vigilance and proactive measures.


This case highlights the critical role that well-trained staff play in identifying and mitigating financial crimes. It is essential for all hospitality businesses to implement comprehensive AML/CTF programs and ensure their staff are well-educated about the signs of money laundering.

If your organisation needs assistance in developing or enhancing its AML/CTF program or training staff to recognise suspicious behaviours, do not hesitate to contact me.

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