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.
11 - Bingo (remote)
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Bingo (Remote) | High | High |
The remote bingo and betting sector will be assessed separately for the purposes of this assessment as the risks differ for both sectors.
For further information relating to the inherent risks (including vulnerabilities, consequences and controls), see our previous 2020 risk assessment.
Sector rating
| 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 | High (3) | High (3) | High (9) | No change | Operator control | Operators staking and winning directly and indirectly on their own products | Low (1) | Medium (2) | Low (2) | No change | Operator control | Poor source of funds checks | High (3) | High (3) | High (9) | No change | Operator control | Inadequate or lack of 'know your customer' (KYC) checks | High (3) | High (3) | High (9) | No change | Operator control | Third party business relationships and business investors | Medium (2) | High (3) | High (6) | New risk rating | Licensing and integrity | Gambling operations run by organised criminals to launder criminally derived funds | Low (1) | High (3) | Medium (3) | No change | Customer | Customer not physically present for identification | High (3) | High (3) | High (9) | No change | Customer | False or stolen documentation used to bypass controls to launder criminally derived funds | Medium (2) | High (3) | High (6) | No change | Customer | Accessibility to multiple remote accounts | Medium (2) | High (3) | High (6) | Decrease in likelihood | Customer | Customers on the sanction list | Low (1) | High (3) | Medium (3) | New risk rating | Customer | Use of third parties or agents to obscure the source or ownership of money gambled by customers and their identities | Medium (2) | High (3) | High (6) | New risk rating | Customer | ‘Smurfing’ | Medium (2) | High (3) | High (6) | New risk rating | Means of payment | Cryptoasset transactions | Medium (2) | High (3) | High (6) | New risk rating | Means of payment | Pre-paid cards | Medium (2) | High (3) | High (6) | Decrease in likelihood | Means of payment | Multiple methods of payment | Medium (2) | High (3) | High (6) | New risk | Means of payment | E-wallets | Medium (2) | Medium (2) | Medium (4) | No change |
Case studies
False or stolen ID
A criminal used stolen ID and debit cards with a gambling operator. The individual deposited funds from several stolen debit cards into the gambling account and then attempted to withdraw the funds to one debit card.
Multiple methods of payment
An individual made deposits into their gambling account from several different debit cards as well as an e-wallet. When withdrawing funds, they only used the e-wallet.
A customer made multiple deposits using numerous debit cards within the first hour of opening their account.
Accessibility to multiple accounts
Following Know Your Customer (KYC) checks an individual was identified as having deposits and credits with several dozen online gambling operators and payment processors during only a few months.
2023 money laundering and risks - Betting (non-remote) Next section
2023 money laundering and risks - Bingo (non-remote)
Last updated: 15 April 2024
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