With FATF set to evaluate Canada this autumn, Dr Ian Messenger says aligning the gaming and payments sectors on AML strategy is no longer optional
When Canada was last evaluated by the Financial Action Task Force (FATF) in September 2016—a process based on a November 2015 on-site visit—the country received a mixed assessment. While its overall AML framework was deemed comprehensive, the report flagged significant weaknesses in beneficial ownership transparency and supervision of non-financial sectors.
Among the areas requiring improvement, FATF underscored gaps related to online casinos, open‑loop prepaid cards, and white‑label ATMs. Fast-forward nearly a decade, and Canada is gearing up for another FATF evaluation in November, placing renewed scrutiny on a rapidly evolving gaming ecosystem.
Today, the convergence of online gambling, digital wallets, and near-instant payments presents new risks for money laundering—especially where payment systems and gaming platforms operate in isolation. According to Dr Ian Messenger, CEO and Founder of the Association of Certified Gaming Compliance Specialists (ACGCS), fragmented oversight and limited cross-sector visibility are among the most urgent challenges facing AML enforcement.
Speaking ahead of the Canadian Gaming Summit, Messenger outlined where Canada’s payments and gaming industries are falling short—and how they can work together to address mounting regulatory expectations.
“We’re seeing continued vulnerabilities in how gambling operators integrate with payment processors,” said Messenger. “Unless there’s robust due diligence on both the customer and the intermediary, these tools can be exploited to layer illicit funds.”
Bridging the compliance gap
Recent audits by FINTRAC, Canada’s financial intelligence unit, have revealed inconsistencies in how anti-money laundering rules are interpreted and enforced across provinces and platforms. The findings echo long-standing concerns about decentralised oversight, particularly in sectors like gambling where regulatory responsibility can vary by jurisdiction.
For Messenger, the root issue lies in a lack of standardisation—particularly between payment providers and gaming operators.
“One of the most effective ways to standardise AML responses is to establish shared protocols for risk assessment, transaction monitoring, and reporting,” he said. “That should apply whether the operator is land-based, online, or hybrid.”
According to Messenger, payment firms must take a more proactive role, embedding AML controls that reflect not only their own obligations, but also the risk profiles of the merchants they serve. That includes moving beyond basic onboarding processes and adopting continuous due diligence, especially in high-risk environments.
Industry-wide collaboration is also essential. Messenger suggests that shared red flag repositories, cross-sector training, and coordinated escalation procedures could all help ensure consistency. Without a common framework, he argues, it becomes harder for regulators to measure effectiveness—and for institutions to detect complex laundering activity across platforms.
Changing the AML mindset
One of the persistent challenges in the gaming industry, according to Messenger, is the tendency to treat AML as a regulatory checkbox rather than a shared risk framework. This, he says, is where the payments industry can shift the narrative.
“The payments industry can play a critical role by framing AML not as a compliance cost, but as a shared defence against financial crime – and ultimately, reputational damage,” said Messenger.
He argues that payment providers should move beyond technical service delivery and instead become strategic compliance partners. That might include offering behavioural analytics, sharing emerging typologies, and helping operators interpret unusual transaction patterns in context.
Stronger onboarding standards also have a role to play. If payment providers set higher expectations for customer due diligence and monitoring, it can influence how gaming operators approach their own compliance strategies.
Messenger also advocates for joint training sessions, where payments and gaming compliance teams review case studies, typologies, and enforcement trends together.
“When both sides are in the same room—virtually or otherwise—it helps embed a shared sense of accountability,” he said.
Data sharing is key to AML reform
A recurring theme in Canada’s AML performance has been fragmentation. Different institutions see different parts of the risk picture—and without structured ways to share that information, meaningful red flags can be missed.
“A payment processor might flag unusual deposits, while a gaming platform sees irregular play behaviour,” explained Messenger. “But without mechanisms to connect those insights, key risks go undetected or unreported.”
To address this, Messenger supports the development of industry consortiums focused on typology sharing and near real-time alerts. He draws comparisons to how fraud bureaus operate in the banking sector or how cyber threat intelligence is shared across industries.
Such systems, he notes, must be underpinned by strong governance and legal safeguards. But they are achievable with the right leadership.
“The payments industry can help define technical standards and data governance protocols that make this kind of collaboration possible,” he said.
Balancing compliance with user experience
The shift toward digital-first gaming has raised expectations around speed and convenience. That creates a balancing act for compliance teams—particularly when verifying the source of funds.
Messenger believes the answer lies in smart segmentation. Not every user poses the same level of risk, and not every transaction requires the same level of scrutiny.
“By segmenting users based on jurisdiction, transaction patterns, or payment method, you can apply enhanced due diligence only where it’s justified,” he said.
Advances in digital ID verification and real-time analytics also offer ways to monitor behaviour without increasing friction for low-risk users. For example, if a player switches payment methods or starts moving funds in a circular pattern, automated prompts can request additional documentation without affecting the broader experience.
Preparing for what’s next
Looking ahead to FATF’s visit in November, Messenger anticipates greater regulatory emphasis on beneficial ownership and source-of-funds transparency. He believes payment professionals must now shift from static checks to dynamic, behaviour-based monitoring systems.
Enhancements to digital identity infrastructure will support this transition, particularly as gaming operators and payment providers look to detect synthetic identities or third-party transactions more efficiently.
But more than any one tool or regulation, Messenger says the key to long-term AML effectiveness is partnership.
“The payments industry needs to move from passive service provision to active collaboration,” he said. “Cross-sector information sharing has long been a weak spot in Canada’s AML regime. That has to change—and now is the moment to do it.”
Source: https://paymentexpert.com/2025/06/13/why-payment-professionals-must-lead-aml-reform-in-gaming/