The Intergovernmental Action Group against Money Laundering (GIABA), has just published this Tuesday, March 15, 2022, a report on "the risks and vulnerabilities in the casino and gambling sector in West Africa" . This document sounds the alarm on the illegal activity of casinos in Benin.

Felicien Houessou

As the financial sector becomes more regulated, criminals are increasingly moving into the non-financial sector, including online casinos and gambling whose vulnerabilities relate to the existence of legal loopholes and the absence of control or supervision mechanisms. The GIABA Assessment Report (2021), entitled Money Laundering: Risks and Vulnerabilities in the Casino and Gambling Sector in West Africa, indicates that casinos are not subject to control and no framework currently exists to control their activity. Contacts between the casinos and the CENTIF are almost non-existent.

There are 4 licensed casinos in Benin. The National Lottery is responsible for ensuring the integrity of National Lottery games, including oversight of the lottery industry. Seven agents are dedicated to the control of the sector, but are not authorized to enter the casinos, and the audits of the gaming establishments are carried out by the police. Indeed, the police have a permanent presence inside the casinos in order to detect any suspicious activity.

The specialized institution of ECOWAS reveals that no Suspicious Transaction Report (STR) has been submitted to date by the operators of casinos in the country; unlike the banks, which have filed, in connection with suspicions of illegal activity of casinos. In 2020, two STRs submitted by two banks helped authorities identify two casinos operating illegally. In 2019, the CENTIF received 903, and their number increases every year.

GIABA Recommendations

The authorities believe that the majority of these games, including games of chance and virtual lottery, do not present money laundering risks. However, GIABA clarifies that the assessment should be reconsidered based on the findings of this report. The illegal activity of casinos constitutes for the country, according to the document, a puzzle which deserves to be solved. The sector needs guidelines.

Considering the vulnerabilities of casinos and games of chance, GIABA urges the authorities to do more to enforce the law, including through the appointment of a national supervisory authority and the implementation of a national level supervision programme. Benin must therefore strive to identify, assess and understand the money laundering risks associated with this sector, in order to provide the appropriate response.