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  3. The 2023 money laundering and terrorist financing risks within the British gambling industry

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.

Published
30 November 2023

Last updated
15 April 2024 - Changes

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  1. Contents
  2. 12 - Bingo (non-remote)

12 - Bingo (non-remote)

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Sector rating

Sector Previous overall risk rating Current overall risk rating
Bingo (non-remote) 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 Medium (2) Medium (2) Medium (4) No change
Operator control Lack of or inadequate ‘know your customer’ (KYC) checks conducted resulting in criminals laundering criminal proceeds Medium (2) Medium (2) Medium (4) No change
Operator control Third party business relationships and business investors Medium (2) Medium (2) Medium (4) New risk
Licensing and integrity Gambling operations being acquired by organised crime to launder criminal proceeds Low (1) Medium (2) Low (2) No change
Licensing and integrity Employees colluding with criminals Low (1) Medium (2) Low (2) No change
Customer Anonymous customers laundering proceeds of crime through gaming machines Low (1) Medium (2) Low (2) No change
Product Electronic Betting Terminals (EBTs) including table-top gaming (either traditionally or via EBT content) Low (1) Medium (2) Low (2) No change
Product Gaming Machines, Category B3 Low (1) Medium (2) Low (2) No change
Product Bring your own device (BYOD) Low (1) Medium (2) Low (2) New risk rating
Means of payment Cash 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 automatic ticket redemption machines (ATR) Medium (2) Medium (2) Medium (4) No change
Means of payment Cashless payment Low (1) Medium (2) Low (2) No change
Means of payment Scottish notes Low (1) Medium (2) Low (2) New risk

Case study

Scottish notes
A customer attempted to exchange a large amount of Scottish notes for English notes at the cash desk but was unable to explain the origin of the funds when asked.

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2023 money laundering and risks - Arcades
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