Guidance
The 2023 money laundering and terrorist financing risks within the British gambling industry
The Gambling Commission's money laundering and terrorist financing risk assessment for the British gambling industry in 2023.
13 - Arcades
Table actions:
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Adult Gaming Centres (AGCs) | Medium | Medium | Family Entertainment Centres (FECs) | Low | Low |
For further information relating to the inherent risks (including vulnerabilities, consequences and controls), see our previous 2020 risk assessment.
Inherent risks
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Low (1) | Medium (2) | Low (2) | No change | Operator control | Lack of competency of key personnel and licence holders which can then be exploited by criminals seeking to launder the proceeds of crime (AGCs only) | Low (1) | Medium (2) | Low (2) | No change | Operator control | Lack of competency of key personnel and licence holders which can then be exploited by criminals seeking to launder the proceeds of crime (FECs only) | Low (1) | Medium (2) | Low (2) | No change | Operator control | Third party business relationships and business investors | Low (1) | Medium (2) | Low (2) | New risk | Licensing and Integrity | Arcade businesses being acquired by organised crime to launder criminal proceeds (AGCs only) | Low (1) | Medium (2) | Low (2) | No change | Licensing and Integrity | Arcade businesses being acquired by organised crime to launder criminal proceeds (FECs only) | Low (1) | Low (1) | Low (1) | No change | Customer | Anonymous customers laundering proceeds of crime through gaming machines (AGCs only) | Medium (2) | Medium (2) | Medium (4) | No change | Customer | Anonymous customers laundering proceeds of crime through gaming machines (FECs only) | Low (1) | Low (1) | Low (1) | No change | Product | Automated ticket redemption (ATR) machines used to facilitate the laundering of criminally derived funds (AGCs only) | Low (1) | Medium (2) | Low (2) | No change | Product | Gaming machines, Category B3 being used to launder criminally derived funds (AGCs only) | Medium (2) | Medium (2) | Medium (4) | No change | Product | Privacy booths (AGCs only) | Medium (2) | Medium (2) | Medium (4) | No change | Product | Privacy booths (FECs only) | Medium (2) | Low (1) | Low (2) | No change | Product | Bring your own device (BYOD) | Low (1) | Medium (2) | Low (2) | No change | Means of payment | Cash transactions | Medium (2) | Medium (2) | Medium (4) | Increase in likelihood | Means of payment | Cashless payments | Medium (2) | Medium (2) | Medium (4) | No change | Means of payment | Ticket-in-ticket-out (TITO) facilities used to launder funds, when used in conjunction with ATR machines (AGCs only) | Low (1) | Medium (2) | Low (2) | No change | Means of payment | Dyed notes | Low (1) | Medium (2) | Low (2) | No change | Means of Payment | Scottish notes | Low (1) | Medium (2) | Low (2) | New risk |
Case studies
Dyed notes
Several hundred pounds of stained notes were found in gaming machines located at an AGC.
Scottish notes
Counterfeit Scottish notes have been found in gaming machines at several venues across the UK.
2023 money laundering and risks - Bingo (non-remote) Next section
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Last updated: 15 April 2024
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