According to the research report by the Council of Europe1, one of the typologies of money laundering through online gambling is the use of multiple accounts and identities to conceal the source and destination of funds. This can be done by opening several accounts under the same name using different IP addresses, or by using false or stolen identification documents to create multiple accounts. Another typology is the use of online gambling platforms that are not regulated or authorized by the jurisdiction where the customer is located, or that do not require know-your-client information from users. This can allow money launderers to access the online gambling services from multiple countries, without being subject to any verification or monitoring by the authorities.
1: Research report - The use of online gambling for money laundering and the financing of terrorism purposes, Council of Europe, April 2013.

According to the ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1, the AML program should be reassessed periodically or when there are significant changes in the business environment, such as:
Expansion of business to new territories: This could expose the business to new risks, regulations, and customers that require different AML policies, procedures, and controls. The AML program should be updated to reflect the new jurisdictions and their AML requirements, as well as to conduct appropriate risk assessments and due diligence on the new markets and customers.
New product offering: This could introduce new vulnerabilities, opportunities, and challenges for the AML program. The AML program should be revised to incorporate the new product features, benefits, and risks, as well as to ensure compliance with any applicable AML rules and standards for the new product.
The other options are not factors that would necessarily lead to a reassessment of the current AML program, unless they have a material impact on the AML risks, objectives, or performance of the business:
Appointment of a new Chief Financial Officer: This could affect the AML program if the new CFO has a different vision, strategy, or approach to AML than the previous one, or if the new CFO has a significant role or responsibility in the AML program. However, the appointment of a new CFO alone does not trigger a reassessment of the AML program, unless there are other changes or issues that warrant a review.
Change of company name: This could affect the AML program if the change of name reflects a change of ownership, structure, or nature of the business that could alter the AML risks, obligations, or expectations.
However, the change of name alone does not necessitate a reassessment of the AML program, unless there are other implications or consequences that affect the AML program.
Change of internal audit team members: This could affect the AML program if the new internal audit team members have different qualifications, skills, or experiences than the previous ones, or if the new internal audit team members have a different scope, methodology, or frequency of auditing the AML program.
However, the change of internal audit team members alone does not require a reassessment of the AML program, unless there are other factors or findings that indicate a need for a review.
References:
ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1
ACAMS CAMS Certification Video Training Course - Exam-Labs
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)

Casinos arehigh-riskformoney launderingdue to theircash-intensive natureandease of moving funds anonymously.
* Option A (Correct):Aprivate company sending funds into multiple patron accountsissuspiciousbecause it may indicatemoney laundering structuringor use ofmules.
* Option B (Incorrect):Betting on multiple events isnormal behaviorunless there isevidence of match- fixing.
* Option C (Incorrect):Large cash buy-ins are common in casinos; however, they become suspicious when coupled withother red flags(e.g., no actual gambling).
* Option D (Incorrect):Transferring winnings may be aregular transactionunless linked tostructured transactions.
Reference:FATF Report on Money Laundering in Casinos (2022), FATF Recommendation 22 (DNFBPs), FinCEN Casino AML Guidance.

While this behavior may warrant scrutiny in certain circumstances, it is not inherently suspicious or indicative of money laundering. In contrast, the other behaviors listed (living beyond one's means, excessive unresolved exceptions, and using company resources for personal gain) may suggest that an employee is engaging in or facilitating money laundering activity.