Detection of structured deposits to evade KYC thresholds

SPORTSBOOK.AML.STRUCTURING.1 · GLOBAL · aml_ctf

Severity

high

Cadence

daily

Region

global

Current status (Apollo Gaming Ltd.)

not evaluated

Requirement

Sportsbook operators must detect and report patterns of structured deposits (multiple deposits below the enhanced-KYC threshold within a 24h or 7d window) and escalate to MLRO within 5 business days.

Source: FATF Rec 16 / 5AMLD applied to sports betting

Evidence specification

Evidence type	Connector	Spec	Acceptance criteria
`aml_event`	`aml-complyadvantage`	{ "rule": "structured_deposit_pattern", "required_fields": [ "player_id", "period", "deposit_count", "total_amount", "escalated_at" ] }	`every flagged player has escalated_at within 5 business days`

Recent evaluations (Apollo Gaming Ltd.)

No evaluation history for this control yet.