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.
6 - Casino (remote)
Table actions:
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Casino (remote) | High | High |
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 | High (3) | High (3) | High (9) | No change |
| Operator control | High monetary thresholds | High (3) | High (3) | High (9) | New risk rating |
| Operator control | High value customer schemes | Medium (2) | High (3) | High (6) | Decrease in likelihood |
| Operator control | Failure to implement a closed loop system | Medium (2) | High (3) | High (6) | New risk rating |
| Operator control | Over reliance on payment providers for carrying out customer due diligence (CDD) measures | 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 | 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) | New risk |
| 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 criminal activity | Low (1) | High (3) | Medium (3) | No change |
| Licensing and integrity | White label providers | High (3) | High (3) | High (9) | No change |
| Customer | Customer not physically present for identification purposes | High (3) | High (3) | High (9) | No change |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds | High (3) | High (3) | High (9) | No change |
| Customer | Accessibility to multiple remote casinos | High (3) | High (3) | High (9) | No change |
| Customer | Customers who appear on financial sanctions lists laundering funds which are subject to an asset freeze | Low (1) | High (3) | Medium (3) | No change |
| Customer | Foreign politically exposed persons (PEPs) using casinos to launder illicit or criminal funds | Medium (2) | High (3) | High (6) | No change |
| Customer | Domestic PEPs using casinos to clean criminal funds identification and verification | Low (1) | Medium (2) | Medium (2) | No change |
| Customer | Customers making numerous low-level transactions to minimise suspicion and evade CDD requirements at the threshold (‘smurfing’) | High (3) | High (3) | High (9) | No change |
| Customer | Use of third parties or agents to obscure the source or ownership of money gambled by customers and their identities | High (3) | High (3) | High (9) | No change |
| Customer | Organised crime gangs | Medium (2) | High (3) | High (6) | New risk rating |
| Customer | Mule accounts | High (3) | High (3) | High (9) | New risk rating |
| Means of payment | E-wallet | Medium (2) | Medium (2) | Medium (4) | No change |
| Means of payment | Crypto asset transactions | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Pre-paid cards | High (3) | High (3) | High (9) | No change |
| Means of payment | Multiple methods of payment | Medium (2) | High (3) | High (6) | New Risk |
| Means of payment | Casinos acting as Money Service Businesses (MSBs) | High (3) | High (3) | High (9) | New risk |
| Product | Peer to Peer Gaming (poker) - Business to Business and Business to Customer | High (3) | High (3) | High (9) | No change |
| Product | High-stakes gambling and feature buy-in slots | Medium (2) | High (3) | High (6) | New risk rating |
| Geographic | Customers from high-risk jurisdictions using casino facilities to launder criminal funds | Medium (2) | High (3) | High (6) | No change |
Case studies
Pre-paid cards
An individual made large deposits using pre-paid cards. When the operator attempted to determine the source of the individual’s funds, the customer claimed that they received their salary in cash.
An individual deposited several thousand pounds with pre-paid cards. Subsequent checks revealed that they were unemployed.
Smurfing
An individual had several failed deposit attempts and then made a series of deposits in low amounts. Once the deposits had been made, the customer requested an immediate withdrawal without any gameplay and then made a further small deposit.
2023 money laundering and risks - Methodology Next section
2023 money laundering and risks - Casino (non-remote)
Last updated: 15 April 2024
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Formatting issue corrected.