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.
3 - Gambling Commission’s risk assessment matrix (ML/TF RAM)
The risk level is represented by a likelihood score multiplied by an impact score to provide and overall risk score.
Likelihood × Impact = Risk
| Likelihood of event occurring | Impact of event occurring | Overall risk (Likelihood × Impact) |
|---|---|---|
| Low (1) | Low (1) | Low (1) |
| Low (1) | Medium (2) | Low (2) |
| Low (1) | High (3) | Medium (3) |
| Medium (2) | Low (1) | Low (2) |
| Medium (2) | Medium (2) | Medium (4) |
| Medium (2) | High (3) | High (6) |
| High (3) | Low (1) | Medium (3) |
| High (3) | Medium (2) | High (6) |
| High (3) | High (3) | High (9) |
Indicators of low overall risk (likelihood and impact) (risk of 1 or 2) are:
- little potential for terrorist financing or money laundering exploitation
- little potential for criminal exploitation and detriment to society
- little or no impact on business environment or wider industry
- potential for minor breaches that are limited in impact and may be short term and which are easily addressed or require very little compliance action
- low cost to implement anti-money laundering or counter-terrorist financing controls
- impact of the risk can be dealt with by routine operations
- little or no concern based on customer and payment method anonymity.
Indicators of medium overall risk (likelihood and impact) (risk of 3 or 4) are:
- some potential for terrorist financing or money laundering exploitation
- some potential for criminal exploitation and detriment to society
- some impact on business environment or wider industry
- potential for breaches that are more difficult or time consuming to address; may be long term or some compliance action needed
- standard cost to implement anti-money laundering or counter-terrorist financing controls
- increased impact of the risk on operations which may subject the operator to a review of their licence
- potential concern based on customer and payment method anonymity.
Indicators of high overall risk (likelihood and impact) (risk of 6 or 9) are:
- high potential for terrorist financing or money laundering exploitation
- high potential for criminal exploitation and detriment to society
- heightened threat to business environment and wider industry
- heightened threat of serious breaches that can lead to significant penalties, fines or sanctions which will need heavy compliance action
- significant cost to implement anti-money laundering or counter-terrorist financing controls
- major impact of the risk on operations. Operators may face significant regulatory action
- national and/or international government inquiry or sustained adverse media coverage
- heightened Money Laundering and TF concerns around anonymous nature of customers and payment methods certain payment methods
Changes in risk
To note how the risk ratings compare to the ratings of the previous assessment, the following descriptions are used in the assessment.
New risk – this refers to identified emerging risks and previously unidentified risks that were not in the previous assessment.
New risk rating – this refers to risks that were previously given an overall risk rating and have now been assigned a likelihood and impact rating.
Decrease or increase in likelihood and impact – noting a change in the risk rating.
Changes to the methodology
The methodology in this edition of the Gambling Commission’s risk assessment has been amended from previous versions to simplify the risk ratings. The risk ratings used in this assessment are low, medium and high. The ratings of very low and very high have been removed, with such risks now being rated low or high.
Previous sectionStages of the money laundering and terrorism financing risk assessment
Last updated: 11 June 2024
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