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.
18 - Terrorist financing
Table actions:
Sector rating
| Sectors | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| All sectors | Low | Medium |
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 understand or take consideration of terrorist financing vulnerabilities and applicable legislation | Low (1) | High (3) | Medium (3) | Increase in impact | Product | Money Service Businesses (MSB) | Low (1) | High (3) | Medium (3) | Increase in impact | Product | Charities and terrorist financing | Low (1) | High (3) | Medium (3) | Increase in impact | Customer | Mule accounts | Low (1) | High (3) | Medium (3) | Increase in impact | Customer | Increase in right-wing terrorism | Low (1) | High (3) | Medium (3) | Increase in impact | Means of payment | Cryptoasset transactions | Low (1) | High (3) | Medium (3) | Increase in impact | Means of payment | Pre-paid cards | Low (1) | High (3) | Medium (3) | Increase in impact | Means of payment | Cash transactions | Low (1) | High (3) | Medium (3) | Increase in impact | Geographic | International terrorism | Low (1) | High (3) | Medium (3) | Increase in impact |
Terrorism 'red flag' indicators
Some potential ‘red flag’ indicators that operators should be alert to, based on evidence reviewed, are:
- a customer’s income or expenditure which is inconsistent with their occupation
- unusual or suspicious religious quotes, or single words or -phrases relating to known terrorist ideology or known numerical associations to terrorism in financial transactions and customer details (social media ‘handle’, web chat, email addresses etc)
- use of multiple foreign bank accounts to conduct transactions.
- unexpected large withdrawals or complete withdrawals of sums and sudden account closure
- transactions are structured to avoid internal threshold or Suspicious Activity Report (SAR) reporting (‘smurfing’)
- MSB usage, including indicators such as: multiple overseas geographical locations destination for transfers, use of third parties in the transaction chain, open loop for foreign exchange transactions i.e., deposits in one currency and requests to withdraw in a different currency and missing details on money transfers
- accounts linked to pre-paid cards
- customer IP address being used by other customers.
2023 money laundering and risk - Gaming machine technical (non-remote and remote) Next section
2023 money laundering and risks - Previous editions of the money laundering and terrorist financing risk assessment
Last updated: 15 April 2024
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