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13 UNLV Gaming L.J. 21 (2022-2023)
Online Gaming: A Good Bet for Money Laundering? An Analysis of Money Laundering in the Canadian Online Gaming Industry

handle is hein.journals/unlvgalj13 and id is 40 raw text is: 






ONLINE GAMING: A GOOD BET FOR MONEY LAUNDERING?
AN   ANALYSIS OF MONEY LAUNDERING IN THE CANADIAN
                   ONLINE GAMING INDUSTRY

                                                     Robin Ketcheson*

                          I.  INTRODUCTION

        Governments, policy makers, and administrative bodies have long been
attentive to the high-risk of money laundering' in land-based gaming facilities.2
Online gaming, though, is still an emerging area and has not yet been subject to
the same attention. Taken together, the emerging nature and rapid progression of
online gaming leads to ambiguity concerning the risks of money laundering, the
effectiveness of current legal regimes, and the need for revision of these regimes.
The  aim of this article is to provide some clarity within this environment of
ambiguity.
        The article proceeds as follows: Part I sets out a synopsis of the current
legal landscapes of both online gaming and money laundering. It also considers
the legislative convergence between  gaming  and  anti-money  laundering
(AML)   laws. Part II discusses the recent expansion of online gaming in
Canada. Part II(A) analyzes the growth of legal online gaming, and Part II(B)
discusses the growth of illegal offshore online gaming. Part III then explicates


* Robin Ketcheson is a third-year Juris Doctor candidate at the Queen's University
Faculty of Law in Kingston, Ontario Canada. This paper would not have been
possible without the support of the late Professor Arthur Cockfield. Professor
Cockfield's support in revising earlier drafts of this paper was invaluable. His
mentorship, wisdom, and kind heart will never be forgotten.
1 Money laundering is the process of converting or transferring funds or other assets
generated from illegal activity in order to conceal their illegal origins. See generally
MARGARET   E BEARE &  STEPHEN SCHNEIDER, MONEY   LAUNDERING IN CANADA:
CHASING DIRTY AND DANGEROUS  DOLLARS ix-xv (Univ. of Toronto Press 2007).
2 See generally Risk Assessment Guidance, GOV'T OF  CAN. (Jan. 4, 2021),
https://www.fintrac-canafe.gc. ca/guidance-directives/compliance-
conformite/rba/rba-eng; PETER M. GERMAN, DIRTY MONEY:  AN  INDEPENDENT
REVIEW  OF MONEY LAUNDERING  IN LOWER MAINLAND   CASINOS CONDUCTED  FOR
THE ATTORNEY  GENERAL OF BRITISH COLUMBIA 27 (2018); Assessment of Inherent
Risks of Money Laundering and Terrorist Financing in Canada, GOV'T OF CAN.
(July        31,        2015),        https://www.canada.ca/en/department-
finance/services/publications/assessment-inherent-risks-money-laundering-
terrorist-financing.html.


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