FIU receives a report from an online casino about conspicuous gambling behavior

FIU receives a report from an online casino about conspicuous gambling behavior

The Financial Intelligence Unit (FIU) recently received a report of conspicuous gambling behavior. The violent reaction during the confrontation reinforced the casino's suspicion that illegal money was possibly being used.

In the Netherlands, the Financial Intelligence Unit (FIU) is the organization to which various reporting institutions must report unusual transactions. This is based on the Money Laundering and Terrorist Financing (Prevention) Act (Wwft). The organization then carries out analyses of the transactions. They make suspicious transactions available to various enforcement and investigation services.

According to the FIU, the gambling sector is an interesting one because the analyses often make a link with gambling. The organization says the following about this on its website

"[the gambling sector is] An interesting sector because our analyses regularly uncover a link with gambling. This link unfolds in several ways. It may be that individuals enter illegality to finance a gambling addiction, that illegally earned money is used consummatively to play, or that the gambling sector is used to disguise illegally earned money. For example, there have been cases where large bills are exchanged for play credit, only to play unusually little."

Report of conspicuous gambling behavior to FIU

Recently, the FIU received a report of conspicuous gambling behavior. Because there is talk of canceling an account, it seems to be about an online casino that has sounded the alarm. Whether this is the first report of conspicuous gambling behavior to the FIU or is merely cited as an example, is not clear.

The FIU has anonymized the report and updated it for clarification:

Customer with customer number 001 loses 21,000 euros in 2 months and exhibits behavior that does not match the customer profile. Customer 001 indicated during customer acquisition that she worked in the hospitality industry as the owner of two restaurants called Restaurant1 and Restaurant2. Income documentation seemed to be correct but, with today's knowledge, would mean that a significant part of the income is used with us. Therefore, decided to contact customer 001 to ask for financial details of the restaurants and how this relates to her playing behavior. The customer reacts very violently to this and subsequently cancels her gaming account. Further investigation was conducted thereon. From public sources, we know that both catering establishments get very bad reviews and in some reviews, it is mentioned that there are few customers (link to public sources added). Therefore, it seems very unlikely to us that both restaurants generate so much income. 
"The lack of being able to determine where the money she played with at our place came from, combined with the deviation from the customer profile and her vehement response to the questions, creates a suspicion that customer 001 may have used illegally earned money."

Report to FIU

This was a report concerning the suspicion of money obtained illegally. Before the advent of a regulated supply of online casinos in the Netherlands, land-based casinos already reported to the FIU if they thought something was wrong. Last year, a case was in the news where Holland Casino had reported to the FIU.

In May 2021, former Minister Dekker announced that there would be a fast lane for reports relating to possible match fixing. You can read the text of the minister's statement at This was to ensure that cases do not remain with the organization and information can flow more quickly to the sports associations.