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.
12 - Bingo (non-remote)
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Bingo (non-remote) | Medium | Medium |
Non-remote bingo as a sector continues to be rated as medium risk for money laundering.
Bingo as a product presents limited risk for money laundering exploitation, however risks associated with monitoring customers in a live premises environment remain in the sector, including the monitoring of gaming machine activity.
The gross gambling yield (GGY) for the non-remote bingo sector for the period April 2024 to March 2025 was £650.4 million. Of this, £424 million was generated through gaming machine activity1.
When gaming machines are used in conjunction with ticket-in-ticket-out machines and automatic ticket redemption machines, there is a risk that staff have less oversight of the transactions.
Many bingo premises operate a membership system. This control can aid in verifying the identity of customers and tracking their activity. In premises where a membership system is not operated, the potential risk posed by anonymous customers is heightened. Bingo licensees who operate AGC-style premises should consider all relevant money laundering and terrorist financing risks to the premises, including those noted in the bingo and arcade sections of this risk assessment.
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 | 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 | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Inadequate know your customer (KYC) checks conducted resulting in criminals laundering criminal proceeds - including failure to obtain additional information following a risk-based approach | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Operator Control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Operator Control | Lack of appropriate customer and transaction monitoring. This includes monitoring play on gaming machines, and across different products | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Lack of closed-loop system | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Premises converted from adult gaming centres (AGC) - these premises may have anonymous customers | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer gambles at multiple premises or operators to disguise the source of their funds | Medium (2) | Medium (2) | Medium (4) | New risk | Means of Payment | Ticket-in-ticket-out (TITO) facilities used to launder funds when used in conjunction with Automatic Ticket Redemptions machines (ATR) | Medium (2) | Medium (2) | Medium (4) | No change | Means of Payment | Cash transactions - this includes the risk of dyed and counterfeit notes | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Means of Payment | Scottish banknotes | Low (1) | Medium (2) | Low (2) | No change | Product | Electronic Bingo Terminals (EBTs) including table-top gaming (either traditionally or via EBT content) | Low (1) | Medium (2) | Low (2) | No change | Product | Gaming machines used to launder criminal funds | Medium (2) | Medium (2) | Medium (4) | Increase in likelihood |
Commission-controlled risks
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations being acquired by organised crime to launder criminal proceeds | Low (1) | Medium (2) | Medium (3) | No change |
Case studies
Scottish banknotes
Scottish banknotes were placed in machines with the potential aim of being paid out in English notes or by using a debit card. In one case, customers placed approximately £6,000 in Scottish notes into gaming machines in a premise.
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 - Bingo (remote) Next section
2026 money laundering and risks - Gambling software (remote and non-remote)
Last updated: 30 July 2026
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