Christchurch Casino fined US$2.9m over compliance failures

The New Zealand High Court found “serious systemic deficiencies” in the casino’s anti-money laundering controls.


New Zealand.- The High Court has approved a NZ$5.06m (US$2.9m) penalty against Christchurch Casino for multiple breaches of New Zealand’s Anti-Money Laundering and Countering Financing of Terrorism Act (AML/CFT Act). The decision follows a Department of Internal Affairs (DIA) investigation that uncovered extensive compliance failures over five years.

Justice Rachel Dunningham said the penalty reflected the “serious systemic deficiencies” in Christchurch Casino’s risk management, record-keeping and customer due diligence systems. The court found that between December 2018 and December 2023, Christchurch Casino failed to properly monitor customer accounts, conduct enhanced due diligence, maintain adequate records, and terminate business relationships when required.

The breaches involved 24 customers who carried out transactions totalling nearly NZ$56m (US$32.6m) without sufficient verification of their source of wealth or funds. Although the casino was not accused of being directly involved in money laundering or terrorism financing, the judge criticised its “casual approach” to its legal obligations, noting that “the failure to act promptly when alerted to the deficiencies can be criticised.”


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The DIA had initially sought a penalty of NZ$6.33m (US$3.69m), but a 20 per cent reduction was applied in recognition of the casino’s cooperation and admission of liability. In its decision, the court said the fine underscored the importance of strict compliance with the AML/CFT Act to preserve public confidence in New Zealand’s financial system.

Christchurch Casino’s internal AML audits reportedly ceased in 2020, and its compliance programme was not reviewed for more than three years despite regulatory requirements. The DIA also identified 285 duplicate transactions and incomplete records of suspicious activity investigations.

The New Zealand High Court found “serious systemic deficiencies” in the casino’s anti-money laundering controls. New Zealand.- The High Court has approved a NZ$5.06m (US$2.9m) penalty against Christchurch Casino for…


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