The Central Bank of the Philippines has issued a guidance paper for BSP-supervised financial institutions on managing risks linked to customers engaged in casino junket operations. The paper is intended to strengthen anti-money laundering, countering terrorism and proliferation financing controls by setting out observed good practices, areas for improvement and red flag indicators for this client segment. All BSP-supervised financial institutions are expected to consider the guidance when enhancing their frameworks to identify, measure and mitigate risks posed by casino junket operators. The guidance draws on a thematic review of select universal, commercial and thrift banks with exposure to casino junket operators and junket players. It found that banks have differing risk appetites, from prohibiting such clients to allowing them subject to conditions, and that controls are generally housed within broader casino, gaming or other high-risk client frameworks. The review found that physical cash and checks remain the main channels for moving funds, with common patterns including time deposits and check deposits between banks, transfers between casinos and personal accounts of financiers, players and junket operators, and foreign exchange transactions between casinos and money service businesses. Good practices included board-level reporting, enhanced due diligence, automated transaction monitoring, link analysis, suspicious transaction reporting, account review or closure, and participation in the Anti-Money Laundering Council's public-private information-sharing initiatives. Areas needing enhancement included a tailored casino junket operator risk framework, stronger onboarding and verification using documents such as casino accreditation, Philippine Amusement and Gaming Corporation approvals and junket agreements, better identification of ultimate beneficial owners and related parties, more targeted alert scenarios and faster investigations, and casino junket operator-specific testing and training. The paper also highlights typologies and red flags to support monitoring, including frequent large cash or check activity without clear economic purpose, use of non-cash instruments such as on-us checks and intra-bank transfers to move casino funds, shared business addresses and ownership structures, and cases where customers initially classified as casino players or financiers were later identified as junket operators through link analysis.

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