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.
10 - Betting (non-remote)
Table actions:
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.
2023 money laundering and risks - Betting (remote) Next section
2023 money laundering and risks - Bingo (remote)
Last updated: 15 April 2024
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