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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.

  1. Contents
  2. 10 - Betting (non-remote)

10 - Betting (non-remote)

Sector rating

Sector Previous overall risk rating Current overall risk rating
Betting (non-remote) High High
Off-course High High
On-course Medium Medium

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 (off-course only) High (3) High (3) High (9) No change
Operator control Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance (on-course only) Medium (2) Medium (2) Medium (4) No change
Operator control Lack of effective customer interaction resulting in a failure to prevent and/or detect Money Laundering or Terrorist financing (ML/TF) (off-course only) Medium (2) High (3) High (6) No change
Operator control Lack of effective customer interaction resulting in a failure to prevent and/or detect ML or TF (on-course only) Medium (2) Medium (2) Medium (4) No change
Operator control Inadequate or lack of 'know your customer' (KYC) checks resulting in criminals laundering criminal proceeds (off-course only) High (3) High (3) High (9) No change
Operator control Inadequate or lack of KYC checks resulting in criminals laundering criminal proceeds (on-course only) Medium (2) Medium (2) Medium (4) No change
Operator control Third party business relationships and business investors (off-course only) Medium (2) High (3) High (6) New risk
Operator control On-course bookmakers providing unlicensed gambling activities (for example, accepting bets over the phone without having the required ancillary betting licence) Low (1) Medium (2) Medium (2) No change
Licensing and integrity Betting operations being acquired by organised crime to launder criminal proceeds (off-course only) Low (1) High (3) Medium (3) No change
Licensing and integrity Betting operations being acquired by organised crime to launder criminal proceeds (on-course only) Low (1) High (3) Medium (3) No change
Licensing and integrity Betting employees acting in collusion with organised criminals to launder criminal funds (off-course only) Medium (2) High (3) High (6) No change
Licensing and integrity Betting employees acting in collusion with organised criminals to launder criminal funds (on-course only) Low (1) Medium (2) Low (2) No change
Customer Unverified customers laundering proceeds of crime through betting (off-course only) High (3) High (3) High (9) No change
Customer Unverified customers laundering proceeds of crime through betting (on-course only) Medium (2) Medium (2) Medium (4) No change
Customer Accessibility to multiple premises and operators (off-course only) High (3) High (3) High (9) No change
Customer False or stolen identification documentation used to bypass controls to launder criminal funds (off-course only) Medium (2) High (3) High (6) Increase in impact
Customer Organised criminal gangs (OCGs) Low (1) High (3) Medium (3) No change
Product Gaming machines used to launder criminal funds (off-course only) Medium (2) High (3) High (6) Decrease in likelihood
Product Self service betting terminals and ticket-in-ticket-out (TITO) machines used to launder criminal funds (off-course only) Medium (2) High (3) High (6) No change
Product Bring your own device (BYOD) Low (1) Medium (2) Low (2) Decrease in impact and likelihood
Means of payment Cash transactions High (3) High (3) High (9) No change
Means of payment Cashless transactions Medium (2) High (3) High (6) Increase in impact
Means of payment Dyed notes Low (1) Medium (2) Low(2) No change
Means of payment Lack of ‘closed loop’ system Medium (2) High (3) High (6) No change
Means of payment Multiple methods of payment Medium (2) High (3) High (6) New risk
Means of payment Scottish notes Low (1) High (3) Medium (3) No change

Case studies

Dyed Notes
Two individuals deposited several hundred pounds of bank notes into a self-service betting terminal which were later found to be stained with what appeared to be anti-theft dye. The individuals were then able to withdraw clean notes from counter staff

Lack of 'closed loop' system and access to multiple premises
An individual deposited several thousand pounds on a self-service betting terminal using a debit card and made bets on several events. The bets were cashed out early before the events had started and the customer was able to withdraw the funds at a different store in the form of cash.

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2023 money laundering and risks - Betting (remote)
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2023 money laundering and risks - Bingo (remote)
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