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.
11 - Bingo (remote)
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Bingo (remote) | High | High |
Remote bingo as a sector continues to be rated as high risk for money laundering.
Bingo as a product presents limited risk for money laundering exploitation, however the sector is exposed to the risks present across the remote sector, in particular because the majority of remote bingo licences are held alongside remote casino licences.
In comparison to other remote sectors, remote bingo has a lower level of transactions. The gross gambling yield (GGY) for the sector for the period April 2024 to March 2025 was £166 million1.
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 and 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 AI.
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 | 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 | High (3) | High (3) | High (9) | 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) | High (3) | High (6) | New risk |
| 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 |
| 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 | Medium (2) | High (3) | High (6) | New risk |
| 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 | Lack of closed loop system | Medium (2) | High (3) | High (6) | 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 | Medium (2) | High (3) | High (6) | New risk |
| 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) | Increase in likelihood (new wording) |
| Customer | Customer gambles with multiple remote operators to disguise the source of their funds | Low (1) | Medium (2) | Low (2) | Decreased in likelihood and impact |
| Customer | Customers making numerous low-level transactions to minimise suspicion and evade thresholds (smurfing) | Medium (2) | High (3) | High (6) | No change |
| 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 | 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 - such as withdrawal after minimal play | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer linked to criminal activity | Medium (2) | High (3) | High (6) | New risk |
| Geographic | Customers who are a resident of or are linked to a high-risk jurisdiction using gambling facilities to launder criminal funds | Low (1) | High (3) | Medium (3) | New risk |
| Means of payment | Multiple methods of payment | Medium (2) | High (3) | High (6) | 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) | No change (new wording) |
| Means of payment | E-wallets | Medium (2) | Medium (2) | Medium (4) | No change |
Commission-controlled risks
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations run by organised criminals to launder criminally derived funds | Low (1) | High (3) | Medium (3) | No change |
Case studies
Scrutiny of source of funds
A customer’s bank statement showed unusual transactions, with the customer regularly receiving small amounts from third parties. Open-source checks identified that the customer was running illegal lotteries through social media.
After a customer’s deposits increased significantly, source of funds checks were conducted and revealed large third-party transfers from a relative. On further enquiry, the customer stated that the funds were received through a power of attorney arrangement which could not be evidenced, raising concerns about the misuse of a vulnerable third party’s funds. The customer’s bank statement showed that funds received from the relative had been used across multiple 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.
References
1 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics
2026 money laundering and risks - Betting (non-remote) Next section
2026 money laundering and risks - Bingo (non-remote)
Last updated: 30 July 2026
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