Judge decision
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The High Court in New Zealand has agreed with the settlement figure reached between Christchurch Casino and the Department of Internal Affairs (DIA) for the casino’s breaches of its obligations under anti-money laundering and terrorism financing laws.

Justice Rachel Dunningham decided that the $5.06m penalty (approximately €2.52m) agreed to between the two parties back in August was “significant” and demonstrates the seriousness of the casino’s deficiencies and operations oversight, according to Radio New Zealand.

A DIA investigation into Christchurch Casino’s AML/CFT compliance between May 2023 and September 2024 found that the casino had failed several of its obligations under the act.

Radio New Zealand notes that transactions totalled around $56m from 24 sample customers and should have triggered the higher level of customer due diligence, terminating business relationships with these patrons.

However, only 11 customers were banned, relationships with them were not terminated, and no enhanced customer due diligence was taken despite bans being issued. Five customers were also connected to one or more suspicious activity reports.

The DIA stated that the casino “failed to establish, implement and maintain a compliant AML/CFT compliance programme, adequately monitor accounts, conduct compliant enhanced customer due diligence, terminate existing business relationships when required, and keep records as required by the act”.

It was not accused of being directly involved in money laundering or the financing of terrorism.

As part of its settlement with the DIA, Christchurch Casino admitted to the breaches and the penalty agreed upon of $5.06m.

Justice Dunningham decided on a penalty of $6.03m, but reduced this figure by 20% to account for the casino’s admission of liability and DIA cooperation.

She said: “While the breaches of the Act were not necessarily deliberate, the failure to act promptly when alerted to the deficiencies can be criticised, as can the somewhat casual approach which was taken by CCL to the extremely important obligations it has under the Act to deter and prevent AML/CFT activities.”

Justice Dunningham noted that Christchurch Casino’s customer account activity monitoring programme had “significant limitations” and was susceptible to error, adding that the casino stopped conducting internal audits on its AML programme after September 2020 and failed to review or revise it between June 2021 and September 2024.

As part of its AML programme, the casino said it would complete internal audits, review and update the programme if required.