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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. 14 - Society Lotteries and external lottery managers (remote and non-remote)

14 - Society Lotteries and external lottery managers (remote and non-remote)

Sector rating

Sector Previous overall risk rating Current overall risk rating
Society lotteries (remote and non-remote) Low Low
External Lottery managers (remote and non-remote) Low Low

Society lotteries and the National Lottery are being assessed separately for the purposes of this assessment as they are two separate sectors and the risks posed differ.

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

Inherent risk

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 Low (1) Low (1) Low (1) Decrease in likelihood
Operator control Third party business relationships and business investors Low (1) Low (1) Low (1) No change
Operator control Licensee failing to transfer lottery proceeds to charities Low (1) Medium (2) Low (2) Increase in impact
Licensing and integrity Operator being acquired by organised crime to launder criminal funds Low (1) Low (1) Low (1) No change
Customer Anonymous customers (Non-Remote) Low (1) Low (1) Low (1) No change
Customer False and stolen identity documentation Low (1) Low (1) Low (1) No change
Customer Customer not physically present (remote) Low (1) Low (1) Low (1) No change
Product Interactive instant win games (online) Low (1) Low (1) Low (1) No change
Products Scratch cards or interactive instant win games Low (1) Low (1) Low (1) No change
Means of payment Cash transactions (non-remote only) Low (1) Low (1) Low (1) No change

Case study

Licensee failing to transfer lottery proceeds to charities
An External Lottery Manager (ELM) was convicted of misusing lottery proceeds. The Chief Executive Officer (CEO) used lottery proceeds to cover the costs of running the business and failed to pass on the proceeds to charities.

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2023 money laundering and risks - Arcades
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2023 money laundering and risks - National Lottery (non-remote and remote)
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