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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. 7 - Casino (non-remote)

7 - Casino (non-remote)

Sector Risk

Table actions:
Sector Previous overall risk rating Current overall risk rating
Casino (non-remote) High High

For further information relating to the inherent risks (including vulnerabilities, consequences and controls), see our previous 2020 risk assessment.

Inherent Risk

Vulnerability Risk Current likelihood of event occurring Current 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 Undermining of the Money Laundering Reporting Officer (MLRO) role by senior management which can intentionally or unintentionally lead to exploitation by money launderers Medium (2) High (3) High (6) Decrease in likelihood
Operator control Lack of competence of key personnel and licence holders which can then potentially be exploited by criminals seeking to launder the proceeds of crime Medium (2) High (3) High (6) Decrease in likelihood
Operator control Lack of adequate and relevant due diligence checks conducted resulting in criminals laundering money High (3) High (3) High (9) No change
Operator control Lack of key person in place responsible for regulatory compliance (as required under regulation 21(1) (a)) Medium (2) High (3) High (6) New risk rating
Operator control Employees who do not hold a personal licence being responsible for ID checks Medium (2) High (3) High (6) New risk rating
Operator control Third party business relationships and business investors Medium (2) High (3) High (6) New risk
Operator control Unlicensed casino employees with known criminal records or suspected criminal activities Medium (2) High (3) High (6) Decrease in likelihood
Licensing and integrity Gambling operations being acquired by organised crime to launder criminal proceeds, or the Ultimate Beneficial Ownership is a criminal or involved in a criminal activity Medium (2) High (3) High (6) No change
Licensing and integrity Employees colluding with criminals High (3) High (3) High (9) No change
Geographic Customer from high-risk jurisdictions using casino facilities to launder money Medium (2) High (3) High (6) No change
Customer Customers who appear on financial sanctions list laundering funds which are subject to asset freeze Low (1) High (3) Medium (3) No change
Customer Foreign politically exposed persons (PEPs) using casinos to clean criminal funds Medium (2) High (3) High (6) No change
Customer Domestic PEPs using casinos to clean criminal funds Low (1) Medium (2) Low (2) No change
Customer False or fraudulently obtained or stolen ID docs used to bypass controls Medium (2) High (3) High (6) No change
Customer Customers breaking up large amounts of cash into small transactions to minimise suspicion and evade customer due ciligence (CDD) requirements at the threshold (‘smurfing’) High (3) High (3) High (9) Increase in likelihood
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) No change
Means of payment Cash transactions High (3) High (3) High (9) No change
Means of payment Casinos acting as Money Service Businesses (MSBs) High (3) High (3) High (9) No change
Means of payment Cryptoasset payments Medium (2) High (3) High (6) No change
Means of payment Cashless payments Medium (2) High (3) High (6) New risk rating
Means of payment Transfer of funds between casino customers Medium (2) High (3) High (6) No change
Means of payment Scottish notes Low (1) High (3) Medium (3) New risk rating
Product Bring your own devices (BYODs) Low (1) High (3) Medium (3) New risk rating
Product Electronic roulette - when used with ticket in ticket out and automatic ticket redemption machines Medium (2) High (3) High (6) No change
Product Gaming machines (all) Medium (2) High (3) High (6) Decrease in likelihood
Product Peer to peer gaming (poker) business to customer (B2C) High (3) High (3) High (6) No change

Case studies

Scottish notes
An individual attempted to exchange a large quantity of Scottish notes at a casino cash desk and their request was denied. They were later seen on the casino’s CCTV inserting large quantities of cash into an electronic gaming machine. The machine was later checked and found to contain several thousand pounds in Scottish notes.

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2023 money laundering and risks- Casino (remote)
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2023 money laundering and risks - Casinos offering Money Service Businesses (MSBs)
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