This week’s briefing covers Canadian gaming-sector enforcement, financial institution investigations and sanctions failures across several jurisdictions, and new FATF findings on the professionalization of underground banking and hawala networks.
FINTRAC imposed penalties of $399,712.50 on New Brunswick Lotteries and Gaming Corporation and $231,826 on Nova Scotia Gaming Corporation following compliance examinations that identified suspicious transaction reporting failures and, in Nova Scotia’s case, deficiencies in compliance policies and risk assessment. Ontario’s AGCO separately issued a $100,000 penalty to NorthStar Gaming for allegedly failing to apply its own enhanced due diligence requirements after a high-risk player reached the operator’s $25,000 lifetime-deposit threshold. The player ultimately deposited approximately $189,395 before NorthStar terminated the account following AGCO inquiries prompted by the player’s connection to a criminal investigation.
The Central Bank of the UAE ordered an urgent forensic review of Banque Misr’s UAE branches after FinCEN proposed a special measure against the bank and identified it as a financial institution of primary money laundering concern. FinCEN estimates that the branches processed approximately US$1.8 billion for 103 companies potentially linked to Iranian shadow banking networks between January 2024 and June 2026. In the UK, the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £4.73 million penalty on Citibank’s London branch for 970 sanctions-breaching payments worth approximately £19.72 million, citing alert backlogs, screening gaps, delayed restrictions and other control failures despite finding no intent to breach sanctions. AUSTRAC, Australia’s financial intelligence unit and AML/CTF regulator, also launched an enforcement investigation into Western Union over its management of high-risk payment channels, customers and affiliates, including transaction monitoring for typologies linked to child sexual exploitation and terrorism financing.
A new FATF report finds that underground banking, hawala and similar service providers have evolved into increasingly professionalized “money laundering as a service” networks, with more than 80% of reporting jurisdictions identifying them among the principal channels used by professional money launderers. Some cases involved more than €500 million laundered within only a few months, while nearly 70% of respondents reported growing use of “digital hawala,” including encrypted messaging, fintech applications, instant payments, virtual assets, stablecoins and purpose-built apps. FATF also identified increasing integration with the formal financial system through bank accounts, payment service providers, virtual IBANs and virtual asset wallets, alongside involvement by professional intermediaries including lawyers, accountants, corporate formation agents, real estate agents and casino operators.
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