Guidance
The 2026 money laundering and terrorist financing risks within the British gambling industry
The Gambling Commission's money laundering and terrorist financing risk assessment of the British gambling industry for 2026.
10 - Betting (non-remote)
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Betting (non-remote) | High | High |
| Off-course | High | High |
| On-course | Medium | Medium |
The non-remote betting sector continues to be rated as high risk for money laundering.
The sector has the potential to be exploited through anonymous customers structuring bets to minimise risk, colluding to bet on fixed events and laundering funds through gaming machines.
Non-remote betting has a high level of transactions. The gross gambling yield (GGY) for the sector in the period April 2024 to March 2025 was £2.5 billion, of which approximately £28 million was in respect of on-course betting1.
Cash is a risk for both on-course and off-course betting, especially when large bets are placed by anonymous customers. In the off-course sector there is potential for open-loop systems to exist where customer activity can take place across different channels (online and in premises) and across premises.
There can be challenges to monitoring customers in the live premises environment across different products, including activity on self-service betting terminals and gaming machines. High-profile events, such as Cheltenham Festival and Royal Ascot, can also present challenges for customer monitoring due to high levels of customer activity and bets being placed by new and unfamiliar customers.
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 (off-course only) | High (3) | High (3) | High (9) | No change | Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance (on-course only) | Medium (2) | Medium (2) | Medium (4) | No change | Operator control | Lack of competence of key personnel and licence holders, which can be exploited by criminals seeking to launder the proceeds of crime (off-course) | Medium (2) | High (3) | High (6) | New risk | Customer | Lack of competence of key personnel and licence holders, which can be exploited by criminals seeking to launder the proceeds of crime (on-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Operator control | Inadequate know your customer (KYC) measures - including failure to obtain additional information following a risk-based approach (off-course) | Medium (2) | High (3) | High (6) | Decrease in likelihood (new wording) | Operator control | Inadequate know your customer (KYC) measures - including failure to obtain additional information following a risk-based approach (on-course) | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Operator control | Lack of appropriate customer activity and transaction monitoring - this includes interactions with customers and monitoring play across different products (off-course) | Medium (2) | High (3) | High (6) | New risk | Operator control | Lack of appropriate customer activity and transaction monitoring (on-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Operator control | Lack of closed-loop system - where appropriate this includes consideration of transactions across channels and premises (off-course and on-course) | Medium (2) | High (3) | High (6) | No change (new wording) | Operator control | Accepting remote bets without the appropriate licence (on-course) | Low (1) | Medium (2) | Low(2) | No change | Operator control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) | No change | Operator control | Inappropriate AML thresholds - including thresholds that are not appropriate for the customer base or are predominantly loss based (off-course and on-course) | Medium (2) | High (3) | High (6) | New risk | Operator control | Failure to appropriately scrutinise source of funds documents (off-course only) | Medium (2) | High (3) | High (6) | New risk | Operator control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | High (3) | High (6) | New risk | Customer | Customer gambles at multiple premises or operators to disguise the source of their funds (off-course and on-course) | Medium (2) | High (3) | High (6) | Reduced likelihood (new wording) | Customer | False or stolen identification documentation used to bypass controls to launder criminal funds (off-course and on-course) | Medium (2) | High (3) | High (6) | No change | Customer | Customer linked to criminal activity (off-course and-on course) | High (3) | High (3) | High (9) | New risk | Customer | Customer presents risks relating to their source of income - including access to third party funds or funds originating from a cash-intensive business (off-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer appears to be a disproportionate spender (off-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer gambles with stolen or fraudulent card (off-course and on-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer displays suspicious or unusual wagering patterns - including placing large bets on 'safe' odds, betting on obscure markets or on events where the integrity has been called into question, as well as use of early 'cash out' features on self-service betting terminals (SSBTs) (off-course and on-course) | Medium (2) | High (3) | High (6) | No change | Means of payment | Cash transactions - this includes the risk of dyed and counterfeit notes (off-course and on-course) | High (3) | High (3) | High (9) | No change (new wording) | Means of payment | Scottish banknotes (off-course and on-course) | Low (1) | High (3) | Medium (1) | No change | Product | Gaming machines used to launder criminal funds (off-course only) | Medium (2) | High (3) | High (6) | No change | Product | Self Service Betting Terminals and Ticket-in-Ticket-Out Machines used to launder criminal funds (off-course only) | Medium (2) | High (3) | High (6) | No change | Product | High-profile events - where there is a significant increase in betting activity there are increased transactions to monitor and previously unknown customers may place large bets | Medium (2) | High (3) | High (6) | New risk | Licensing and integrity | Betting employees acting in collusion with organised criminals to launder criminal funds (off-course only) | Medium (2) | High (3) | High (6) | No change |
Commission-controlled risks
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Betting operations being acquired or run by organised criminals to launder funds (on-course only) | Low (1) | High (3) | Medium (3) | No change | Licensing and integrity | Betting operations being acquired or run by organised criminals to launder funds (off-course only) | Low (1) | High (3) | Medium (3) | No change |
Case studies
Scottish banknotes
Scottish banknotes have been placed in machines with the potential aim of being paid out in English notes or by debit card, examples include:
- a customer placed approximately £600 in Scottish banknotes into a gaming machine, and winning funds were paid out to a debit card
- a group of betting premises in the same area noted a significant increase in customers using Scottish banknotes over the course of several days. Approximately £8,000 in Scottish notes were accepted by the premises during this period
- a premises identified £3,000 in Scottish banknotes in gaming machines placed by unknown customers.
Lack of 'closed loop' system
A customer loaded £4,000 cash into a self-service betting terminal and requested that the funds be debited to their card.
Employees colluding with customers
A customer who had been suspended due to not providing requested documentation was able to place bets by transferring money to staff members bank accounts who then proceeded to place cash bets on the customer’s behalf.
Gaming machines
A Commission investigation found that a licensed operator did not have appropriate systems in place to monitor customer activity on B3 gaming machines, as the monitoring reports did not allow the operator to assess customers’ overall spend.
A customer employed by a cash-intensive business used cash to load a gaming machine but, after minimal play, requested funds be paid back to their debit card.
References
1Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics.
2026 money laundering and risks - Betting (remote) Next section
2026 money laundering and risks - Bingo (remote)
Last updated: 30 July 2026