Crown "borrowed" the reputation of an independent consultant in order to appease Victoria's gaming regulator, a royal commission has heard.
The inquiry into whether Crown remains suitable to keep its licence for its Melbourne operations was on Tuesday told the James Packer-backed group waited until the last minute before engaging an expert to "convey a sense of reform".
The Victorian Commission for Gambling and Liquor Regulation in July 2018 recommended Crown within 12 months create procedures to better scrutinise where the money used by players in junket groups came from.
Junket operators brought customers to the casino in exchange for a cut of their spending, and while Crown would track a group's money, individual players were afforded anonymity.
Crown in early June 2019 instructed Neil Jeans, who runs Initialism, a specialist anti-money laundering consultancy firm, to review its response to the VCGLR recommendation.
Mr Jeans told the inquiry his instructions from Crown were not only made weeks out from the VCGLR deadline, but were also "very limited" in their terms of reference.
As a result, he spent about "half a day" working on a letter, which was sent to the VCGLR, and did not charge Crown for this work.
"Do you feel that Crown was borrowing your reputation to get back to the VCGLR to satisfy one of their recommendations?" counsel assisting Meg O'Sullivan asked Mr Jeans.
He said yes.
Ms O'Sullivan then asked whether by providing limited terms of reference Crown was really engaging in "window-dressing" to "convey a sense of reform", when no actual reform was made.
"They asked me to produce a report and may have pretended that report was more than it actually was," Mr Jeans responded.
The inquiry also heard Crown ignored a recommendation made by Initialism to review bank accounts linked to its Melbourne and Perth casinos that could be exposed to money laundering for 13 months.
This review could have been completed by now if started when first recommended in August 2019, Mr Jeans said.
Speaking with Crown's former anti-money laundering chief, Louise Lane, Mr Jeans recommended the group review these accounts due to 114 instances of "structuring" between July 2013 and December 2019.
Structuring involved the depositing of funds into a casino patron's account multiple times per day at different but nearby locations.
This, he said, was done in order to avoid a $10,000 reporting threshold that would trigger the identification of the depositor.
Mr Jeans said there had been 53 potential instances of "structuring" connected to Crown Melbourne from July 2013 to December 2019.
He was not formally instructed to undertake a money laundering risk assessment for Crown's Melbourne and Perth casinos until October 2020.
But after providing the firm with a draft assessment the following month, Initialism received no response.
Mr Jeans said this was likely due to a lack of resources at Crown's anti-money laundering team.
He also said this review could have been completed and made available to the Victorian inquiry if it began in August 2019, when he first suggested it to Ms Lane.
Mr Jeans said about $15 billion was laundered in Australia each year, with the gaming industry one of the last avenues open to criminals to "clean" their money.
"If I was a criminal entrepreneur (the gaming industry) would certainly be high on my list of channels to use," he told the inquiry.
The Victorian inquiry, set up by the Andrews government and overseen by Federal Court judge Raymond Finkelstein QC, began its public hearings last week.
It continues on Wednesday.