Tumas Gaming has been hit with a €233,156 fine for breaching money laundering regulations, with the FIAU uncovering players splashing hundreds of thousands in cash with little oversight.
An investigation by the FIAU uncovered that Tumas Gaming failed to implement several measures to address major threats to their money laundering supervision – namely the extent of untraced cash drops from particular players and the possible collusion with customers.
Tumas Gaming is owned by Tumas Group, which was led by Yorgen Fenech until his arrest in connection with the assassination of journalist Daphne Caruana Galiza. Its COO Patrick Demanuele is currently under investigation as part of a money laundering and trading-in-influence investigation.
The FIAU uncovered that there were serious difficulties in keeping track of customer risk assessments, with the unit also questioning the accuracy of certain risk ratings of certain players. In fact, the unit found that one local player who paid exclusively in cash was never subject to a risk assessment.
Inconsistencies were also found with regards to Tumas Gaming’s ability to ensure that the risk assessment on customers remained up to date.
The company’s due diligence on customers was also subject to criticism by the FIAU, who noted that the company failed to identify and address the risks arising from particular, “which most often than not related to inconsistencies between customer information and gaming activity, links to high-risk jurisdictions and cash transactions”.
The due diligence forms, the FIAU said, were vague and relied solely on Source of Wealth (SOW) declarations made by the players. In most cases, these declarations were generic and followed a tick-based approach.
In one case, a high-risk player, who had been charged over failing to declare large amounts of cash, was still able to deposit €416,457 at the cash desk and drop €309,370 on live tables. The person’s SOW said they were a marketing consultant, with a business card that carried a different name to the player being used as proof.
In another, another high-risk player, deposited €407,805 at one of the cash desks over a six-day period in January 2020 and dropped a further €212,650 through their relationship with Tumas Gaming. The player, who registered his annual income at €100,000, was allowed to play despite being uncooperative when asked for further information.
Another case involved a housewife who dropped off €41,855 in cash in 10 months and €37,635 in a 10-day period, but was still considered a “low-level risk”.
A main cause for concern for the FIAU was the lack of redress from players leaving positive balances on slot machines and other players continuing the game – allowing an environment for collusion on creating layers of transactions between parties.
Meanwhile, the company also did not conduct the necessary analysis on players from questionable jurisdictions like Saudi Arabia, Russia, Singapore, Libya, Bangladesh, China, Serbia, Turkey, Philippines, Yemen, Dubai, Pakistan, Ghana, Kuwait, and Tunisia.
A separate key issue the FIAU found was no record of politically exposed persons was kept. Tumas Gaming also failed to obtain information on player’s annual income, which would be crucial to see if they were playing in line with what they can actually payout.
One player, who was listed as retired, had claimed that their husband, who worked as a driver and a waiter was funding the gameplay. However, this was rubbished by bank statements who also noted that this person mostly played with cash deposits.
The issue is not new for Tumas Gaming. Between 2008 and 2020, one player, who said his annual income was a maximum of €40,000, had deposited €972,622 at the cash desk and a further €824,111 on live games. Still no request to verify the source was issued.
Meanwhile, a well-known businessman who operates in the real estate sector and visited the casino in excess of 300 times, had dropped €988,700 and lost €164,735 between 2016 and 2018. Despite the massive outlay, he was only asked to fill in a due diligence report in March 2020.
Beyond the issues, Tumas Gaming’s record-keeping was also criticised by the FIAU. The company claimed that its customer information was stored on a hard disk. However, the hard disk was later found to be corrupted – so identification and verification checks could not be produced.
Due to the “serious” breaches, the FIAU handed a €233,156 fine and an action plan to address the glaring issues in the company.
What do you think of the fine and the report’s findings?