New Regulatory Requirements Target Illicit Financial Flows in the Digital Gambling Sector

Peru has implemented a new anti-money laundering framework targeting online gambling, marking a significant step in strengthening oversight of a sector increasingly exposed to financial crime risk. The framework introduces enhanced obligations for licensed online gambling operators, including customer due diligence, real-time transaction monitoring, and strict reporting requirements aimed at disrupting illicit financial flows.

The measures reflect a broader regional and global trend toward tightening AML controls in high-risk digital and cash-intensive industries.

Why Online Gambling Presents Elevated AML Risk

Online gambling platforms present unique money laundering vulnerabilities due to high transaction volumes, rapid fund movement, remote access, and the potential for anonymity. Criminal actors can exploit these features to:

• Place illicit funds through betting activity
• Layer transactions using rapid deposits and withdrawals
• Integrate funds by cashing out as apparent winnings

Regulators globally have identified online gambling as a sector requiring enhanced supervision and tailored AML controls.

Overview of Peru’s New AML Framework

Peru’s updated AML framework brings online gambling operators firmly within the scope of regulated financial crime controls. The framework requires operators to implement comprehensive systems and governance measures aligned with international AML standards.

Key objectives of the framework include increasing transparency, improving detection of suspicious activity, and strengthening cooperation with supervisory and law enforcement authorities.

Customer Due Diligence Requirements

Under the new framework, online gambling operators must apply robust customer due diligence measures. These include:

• Verifying customer identity prior to account activation
• Understanding the nature and purpose of the gambling relationship
• Applying enhanced due diligence for higher risk customers
• Maintaining up-to-date customer information

These requirements are designed to reduce anonymity and ensure operators understand who is using their platforms.

Real Time Transaction Monitoring

A central feature of the framework is the requirement for real-time monitoring of transactions and betting activity. Operators must deploy systems capable of identifying unusual or suspicious patterns, including:

• Rapid movement of funds
• Unusual betting behavior inconsistent with customer profiles
• Repeated deposits and withdrawals with minimal gameplay

Real-time monitoring strengthens the ability to detect laundering activity before funds exit the platform.

Reporting and Record Keeping Obligations

The framework imposes strict reporting and record-keeping obligations on operators. This includes:

• Timely reporting of suspicious transactions to the competent authority
• Retention of transaction and customer records for regulatory review
• Cooperation with supervisory inspections and investigations

Failure to meet reporting obligations may result in significant regulatory sanctions.

Governance and Compliance Expectations

Beyond technical controls, the framework places strong emphasis on governance. Operators are expected to:

• Appoint responsible AML compliance officers
• Maintain documented AML policies and procedures
• Train staff on money laundering risks specific to online gambling
• Conduct regular risk assessments and independent reviews

These measures reinforce accountability and ensure AML controls operate effectively in practice.

Implications for Operators and Financial Institutions

The new framework has implications not only for gambling operators, but also for financial institutions that provide payment services to the sector. Banks and payment providers must ensure that their own risk assessments reflect the strengthened regulatory environment and the evolving risk profile of online gambling businesses.

Institutions may face increased expectations around due diligence, monitoring, and ongoing oversight of gambling-related clients.

Alignment with International AML Standards

Peru’s approach aligns with international standards set by bodies such as the Financial Action Task Force, particularly in relation to risk-based supervision, sector-specific controls, and real-time monitoring expectations for higher-risk activities.

This alignment supports Peru’s broader efforts to combat illicit finance and enhance the integrity of its financial system.