The ethical casino? Crime, corruption, and the fight for integrity in the gaming industry

Introduction

I spent a career inside the legal and regulatory machinery of the casino industry – advising clients, drafting policy, and watching as global gaming markets expanded with breathtaking speed. But over time, it became clear that something darker was unfolding beneath the surface. Junket operations, once sold as harmless intermediaries, had become financial conduits for transnational crime. They weren’t just bending the rules – they were redesigning the game.

In this article I outline how casino gambling reached this point, how it pulled itself back from the brink and how we can all contribute to preserving it for the future.

Random lapses or a broader pattern?

While researching my latest book, Casino Redux, I unearthed evidence to document that evolution. Unlike Nicholas Pileggi’s portrait of the American Mafia, this story doesn’t center on a single city or a single set of actors. It follows the rise of the Chinese Triads as they embedded themselves in casinos from Sydney to Vancouver, from Macau to the Golden Triangle. These weren’t, for the most part, old-world gangsters with visible scars and whispered threats. They were discreet, digitally fluent, and globally networked – operating with the cooperation, or the wilful blindness, of people who should have known better.

Why write it now, in retirement? Because I could finally say what needed to be said. Because this industry – licensed by the public, protected by law – remains too often shielded by silence and technicality. And because if the next generation of gaming lawyers, regulators, and executives is to inherit something worth preserving, they must first understand what was allowed to grow in plain sight.

My research took me beyond the velvet ropes of VIP baccarat rooms to expose a calculated system: a transnational criminal infrastructure designed to launder money and evade currency controls.

These weren’t random lapses. They followed a pattern – systematic, intentional, and global in scope. At a Vancouver casino, street-level couriers hauled hockey bags stuffed with drug cash into casinos, where Chinese high rollers exchanged the dirty money into c lean c hips. In Sydney, Crown Resorts funnelled funds through bank accounts disguised as legitimate investments but used in laundering schemes like “cuckoo smurfing.” And in the Golden Triangle, casino resorts functioned not just as gambling halls, but as fronts – processing centers for trafficking networks dealing in narcotics, humans, and endangered wildlife – sustained not only by criminal syndicates, but by compromised officials.

The geography changes. The playbook does not: cash-stuffed duffels in Vancouver, forged accounts in Sydney, trafficking fronts in Southeast Asia. Each is a node in a single, coordinated system – profitable, protected, and criminal.

Junkets began as recruitment tools for high-stakes players. They evolved into unregulated banking systems, tailor-made for organized crime. Born in Macau, these operations spread across Australasia, North America, and Europe, embedding themselves in brick-and-mortar casinos and digital platforms alike.

What unfolded was not a scattering of bad actors or occasional enforcement lapses. It was a fully entrenched criminal infrastructure, reinforced by political complicity. Billions in illicit funds flowed through casinos that, on paper, appeared compliant – but in practice, had become essential staging posts in the laundering pipelines.

These were not isolated failures but the normalization of misconduct – especially in jurisdictions where the question wasn’t whether the money was dirty, but whether asking was worth the trouble. As long as the junkets delivered and the profits kept on flowing, few looked beyond the drop box.

Money, apathy, erosion

This isn’t merely a story of an industry gone astray. It is a history lesson, twice told, in how money, regulatory apathy, and ethical erosion created fertile ground for criminal empires to thrive in plain sight.

The Triads’ ascent from their Macau stronghold to their seamless integration into a global industry was driven more by profits than by principles. I have explored the explosive growth of Macau’s gaming sector and the entangled legacies of Stanley Ho, Broken Tooth Wan, and Alvin Chau. Foreign operators entered a casino market already mired in violence and corruption – and rather than reform it, they conformed to its norms, offloading legal risk onto junkets, skirting Chinese law, and looking the other way as those same intermediaries deepened ties to the criminal underworld.

When transnational organized crime is allowed to flourish within the casino industry two things happen. First, casino activity moves relentlessly up. At first, this can feel like good news for operators and regulators who preside over increased profits and taxes. But over time, it breeds a dependency on criminal activity that explains why so many have failed to tackle it. It also raises the stakes for the criminals who have to protect their lucrative operations from rivals and any regulators looking to close them down. The history of the industry is punctuated by occasions when turf wars spilled over into murderous feuds between Triad gangs on the streets of Macau and elsewhere. And it is a single-minded regulator who is prepared to shrug off death threats in pursuit of his goal to keep crime out of casinos.

Even if violence doesn’t ensue, there is a second and potentially even more devastating result of criminal infiltration. It positions casino customers right next to bad actors. These characters have no thought or consideration for the welfare of players. They are motivated only by money. Thus, their involvement is almost always accompanied by an upturn in loan sharking and other forms of exploitation against regular customers. Above all, the association of crime with the casino industry breaks the vital public confidence and trust on which the industry ultimately relies.

This isn’t just a story about criminal ingenuity. It is a warning – to look beyond the glitz and into the shadow economies that flourish beneath the lights. Gaming is no longer a regional pastime. It is a global enterprise – interconnected, opaque, and increasingly exposed to criminal forces far beyond the reach of traditional oversight.

And still, the public image of the casino remains carefully staged. Industry leaders tout their regulatory credentials. But if these frameworks exist, how do such profound breaches occur not in darkness, but in full view?

For corruption to flourish, two failures must align: government oversight must falter – through negligence, political compromise, or wilful blindness – and casino operators must either tolerate or collaborate with criminal influence.

This is not merely a question of competence. It is about integrity. In Manila, stolen funds from a North Korean cyber-heist were laundered through a VIP room – a direct consequence of hollow anti-money laundering enforcement.

Rules exist. But without resolve, regulation is performance. It protects nothing. It hides everything.

So if regulators can’t hold the line, who can? Can an industry built on risk and reward regulate itself? Especially when accountability threatens the very profits that sustain it. Can ethical restraint survive when the incentives to look away are overwhelming?

These aren’t academic questions. They are real-world tests – for lawyers, regulators, and executives navigating an industry that straddles the line between legitimacy and lawlessness.

To confront them, we must discard the romanticized image of organized crime. The old tropes of Mafia skims and cheap buffets have given way to something far more sophisticated. The Triads fused ancient underworld practices with modern financial tools. They didn’t just manipulate the system – they became part of its design.

Alliances with casino insiders became pipelines for the very crimes regulators claimed they were preventing – money laundering, tax evasion, bribery, trafficking. That collusion threatens the foundational compact upon which casinos operate. These institutions don’t exist by market entitlement. They exist by public charter. In exchange for privileged access and legal protections, they accept obligations: to ensure fairness, prevent abuse, and reject criminal entanglements.

When that bargain collapses, legitimacy unravels – and with it, the legal foundation on which the industry rests. The compact is not immutable; it is conditional, upheld by public trust. And when that trust breaks, public opinion doesn’t deliberate – it indicts. Swiftly. Often irreversibly.

And yet, as the regulators faltered, another line of defense remained: the legal profession.

For lawyers working in this space, the stakes are high. This is more than a matter of legal procedure. It is a matter of responsibility. We are not mere observers of the public compact – we are its custodians. And with that comes an obligation – not just to the letter of the law, but to the trust that gives the law its power.

Too often, lawyers serve not as gatekeepers but as architects of plausible deniability – wrapping vice in procedure until principle disappears. By taking refuge behind legal formalism, the industry has allowed its ethical foundation to decay.

An ethical casino doesn’t ask, “What can we get away with?” It asks, “What should we be doing?”

That means building systems that uncover misconduct – not conceal it. It means asking better questions – and having the courage to act, even when profits are at stake.

My research found an industry standing at a moral crossroads. Its players divide into three camps. First, the immoral – those who knowingly breach the rules, viewing ethics as obstacles to profit. Next, the amoral – those who adhere to the letter of the law while sidestepping its spirit. And finally, a quieter third group – smaller in number but vital to the industry’s survival: the moral actors. They do more than comply. They interrogate. They take ownership, even when it’s inconvenient. And they measure success not by quarterly returns, but by whether their institutions still reflect the values the public entrusts them to uphold.

If the casino industry is to be saved – and to be worth saving – it must be redefined by that quiet, smaller, third group.

Whether drafting policy, advising clients, or auditing compliance, lawyers play a pivotal role. You don’t need a badge to draw the line. You need sharper instincts – and the will to act on them.

• Does this transaction reflect not just legal compliance, but ethical integrity?
• Are we reinforcing public trust, or rationalizing its erosion?
• Do we understand the networks operating just beyond our sightlines?

Conclusion

Above all, this is about restoring trust – between law and the public, between regulators and the regulated, and within the profession itself.

The Romans had a saying: “Nothing is more unpredictable than the mob, nothing more obscure than public opinion.” In gaming, that volatility carries a cost. Regulatory failure provokes backlash. And when public trust collapses, no audit, no statute, no courtroom victory can restore what’s lost – not in the eyes of the public, and not in the soul of the industry.

When trust collapses, the industry doesn’t just lose credibility. It may lose its fiat to exist. And no amount of legal brilliance can buy it back.