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.
9 - Betting (remote)
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Betting (remote) | High | High |
The remote betting sector continues to be rated high risk for money laundering.
The sector has the potential to be exploited through customers structuring bets to minimise risk, peer-to-peer activity and customers colluding to bet on events that have been fixed by participants.
Remote betting has a high level of transactions with the gross gambling yield (GGY) for the sector in the period April 2024 to March 2025 totalling £2.6 billion1.
The remote sector faces challenges as a result of customers not being present for verification purposes. This includes the use of fraudulent documentation to bypass know your customer (KYC) controls, as well as the risk of mule accounts being created. Developments in artificial intelligence (AI) tools create further difficulties. The Commission is aware of an increase in the scale and sophistication of attempts to bypass KYC checks using false documentation, deepfake videos and face swaps generated by artificial intelligence.
The remote sector is also exposed to financial flows from higher risk payment methods, including e-wallets, pre-paid methods and the presence of funds linked to cryptoassets. Further risks can be present when customers use multiple methods of payment, or an open-loop system is in operation.
Risks
| Vulnerability | Risk | Current likelihood of event occurring | Current 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 | Lack of competency of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | High (3) | High (6) | No change |
| Operator control | Inadequate ‘know your customer’ (KYC) measures on customers who are not physically present for verification - this includes the failure to obtain additional information following a risk based approach | High (3) | High (3) | High (9) | No change (new wording) |
| Operator control | Lack of appropriate customer and transaction monitoring | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Inappropriate AML thresholds - including thresholds that are not appropriate for the customer base or are predominantly loss based | High (3) | High (3) | High (9) | No change (new wording) |
| Operator control | Pool betting operators staking and winning directly and indirectly on their own products | Low (1) | Medium (2) | Low (2) | No change (new wording) |
| Operator control | Inadequate due diligence on white-label partnerships | High (3) | High (3) | High (9) | No change (new wording) |
| Operator control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) | New risk |
| Operator control | Inappropriate controls relating to linked or duplicate accounts - this includes identifying linked accounts and, where multiple accounts are permitted, applying controls across accounts | High (3) | High (3) | High (9) | New risk |
| Operator control | Lack of closed-loop system | Medium (2) | High (3) | High (6) | 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 (new wording) |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds - this includes the use of AI tools to generate documents or videos | High (3) | High (3) | High (9) | No change (new wording) |
| Customer | Customer gambles with multiple remote operators to disguise the source of their funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| 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 | Third party use of customer accounts to obscure the source of funds and identity of the user - this includes the creation of mule accounts and the use of agents | High (3) | High (3) | High (9) | No change (new wording) |
| Customer | Customers making numerous low-level transactions to minimise suspicion and evade thresholds (smurfing) | Medium (2) | High (3) | High (6) | Decrease in likelihood (new wording) |
| Customer | Politically exposed persons (PEPs) | Medium (2) | High (3) | High (6) | No change | Customer | Customer presents risks relating to their source of income - including access to third party funds or funds originating from a cash-intensive business | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) | New risk | Customer | Customer uses a third-party payment method that is not in their name | Medium (2) | High (3) | High (6) | 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 | Medium (2) | High (3) | High (6) | New risk | Customer | Customer linked to criminal activity | High (3) | High (3) | High (9) | New risk | Geographic | Customers who are a resident of or are linked to a high-risk jurisdiction using gambling facilities to launder criminal funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Means of payment | E-wallets | Medium (2) | Medium (2) | Medium (4) | No change |
| Means of payment | Cryptoasset transactions | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Pre-paid methods including vouchers and cards - this payment method can make it difficult to identify the source of funds | Medium (2) | High (3) | High (6) | Decrease in likelihood (new wording) |
| Means of payment | Multiple methods of payment | Medium (2) | High (3) | High (6) | No change |
| Product | Peer-to-peer betting - there is a risk of the transfer of funds through betting exchange and small pool groups | High (3) | High (3) | High (9) | No change (new wording) |
| Product | Unregulated betting events | 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 |
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 | Low (1) | High (3) | Medium (3) | No change |
Case studies
Suspicious wagering
A customer displayed suspicious betting patterns, placing high stakes bets with low odds and cashing out bets early. The betting activity was a change from the normal activity on the account and the customer refused to cooperate with requests for documents.
Mule accounts
A customer who previously had minimal activity on their account made a £10,000 deposit in the early hours of the morning. The customer then requested to withdraw the funds without wagering them. Source of funds enquiries revealed that the customer was a student who was not in receipt of a regular income. The customer had also received multiple transfers from third parties and was suspected of money mule activity.
Scrutiny of source of funds
A student with no formal employment was asked for source of funds information by an operator as part of know your customer (KYC) checks. The student provided a bank statement which showed them making large cash deposits into their bank account, which was followed by smaller transfers to other individuals with the payment references naming other gambling operators.
Multiple accounts and false or stolen identity documents
A customer deposited approximately £40,000 over the course of 6 months, creating accounts using the details of 5 different individuals.
Circumvention of identity verification controls
A customer, whose account had previously been blocked due to suspicion of money laundering, was able to circumvent identity verification checks at sign-up and create a new account. Operator controls were insufficient to identify small discrepancies within customer sign-up data fields.
Inadequate due diligence on white-label partnerships
A Commission investigation found that a licensed operator with white-label partnerships had failed to carry out effective due diligence on the ownership of the third party, as well as the source of funds for the business relationship. The operator had also not sufficiently considered whether any activity by the white-label partner was illegal, either in Britain or the territory in which it was conducted.
References
1 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics.
2026 money laundering and risks - Casinos offering Money Service Businesses (MSBs) Next section
2026 money laundering and risks - Betting (non-remote)
Last updated: 30 July 2026
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