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.
7 - Casino (non-remote)
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Casino (non-remote) | High | High |
The non-remote casino sector continues to be rated as high risk for money laundering.
The casino environment allows high stakes wagering, as well as products vulnerable to collusion. Peer-to-peer activity, such as poker, can also be exploited to facilitate the exchange of funds between customers and so carries a higher ML and TF risk.
The level of activity in non-remote casinos has increased since the previous risk assessment. In the period April 2022 to March 2023, gross gambling yield (GGY) in the sector was £810 million and, in April 2024 to March 2025, it rose to £934 million. However, the overall level of funds moving in the sector has not returned to its pre-COVID pandemic levels1.
The non-remote sector faces challenges of applying effective controls in the live environment of the premises. For example, where casinos allow customers to enter without formal identification, they need to determine how to ensure customers’ identities are verified and customers are actively monitored in line with the requirements of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations) (opens in new tab).
The National Risk Assessment of Money Laundering and Terrorist Financing (opens in new tab) (PDF) (the NRA) identified the casino sector as having a high risk of exposure to cash and noted that, while the use of cash for legitimate transactions has declined, it remains widely used by criminals2. Risks are also posed by other payment methods available in casinos, for example where a customer deposits using a terminal and there is potentially less oversight than funds deposited at a cash desk. There is also a risk posed by customers using Money Service Business (MSB) facilities - further details can be found in the section Casinos offering Money Service Businesses (MSBs).
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 | MLRO lacks the independence and resources to uphold their responsibilities | Medium (2) | High (3) | High (6) | No change (new wording) |
| Operator control | Lack of competence of key personnel and licence holders which can potentially be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | High (3) | High (6) | No change |
| Operator control | Lack of adequate and relevant due diligence checks conducted resulting in criminals laundering money | High (3) | High (3) | High (9) | No change |
| 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) | New risk |
| Operator control | Lack of appropriate customer monitoring - this includes the risk profiling and ongoing monitoring of customers in a business relationship, as well as the monitoring of customers where CDD has not been completed (for example where customers are allowed entry without formal identification) | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Lack of closed-loop system | 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) | High (3) | High (6) | New risk |
| Customer | 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 | 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 | Foreign politically exposed persons (PEPs) using casinos to launder criminal funds | Medium (2) | High (3) | High (6) | No change |
| Customer | Domestic PEPs using casinos to launder criminal funds | Low (1) | Medium (2) | Low (2) | No change |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds | High (3) | High (3) | High (9) | No change |
| Customer | Domestic PEPs using casinos to clean criminal funds | Low (1) | Medium (2) | Low (2) | No change |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds | High (3) | High (3) | High (9) | Increase in likelihood |
| Customer | Customers breaking up large amounts of cash into small transactions to minimise suspicion and evade customer due diligence (CDD) requirements at the threshold (‘smurfing’) | Medium (2) | High (3) | High (6) | Decrease in likelihood |
| Customer | Use of third parties to obscure the source or ownership of money gambled by customers - this includes agents and money mules | Medium (2) | High (3) | High (6) | No change (new wording) |
| 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 displays suspicious or unusual wagering patterns – such as minimal play and hedging bets | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer gambles at multiple premises or operators to disguise the source of their funds | 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 high-risk jurisdictions using casino facilities to launder criminal funds | Medium (2) | High (3) | High (9) | No change (new wording) |
| Means of payment | Terminals used to facilitate payments - funds received via this method may not be scrutinised as closely | Medium (2) | Medium (2) | Medium (4) | New risk |
| Means of payment | Cash transactions - this includes the risk of dyed and counterfeit notes | High (3) | High (3) | High (9) | No change (new wording) |
| Means of payment | Casinos acting as money service businesses (MSBs) | High (3) | High (3) | High (9) | No change |
| Means of payment | Cryptoasset transactions | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Scottish banknotes | Low (1) | High (3) | Medium (3) | No change |
| Means of payment | Ticket-in-ticket-out (TITO) enabled machines used to launder criminal funds when used with an automatic ticket redemption (ATR) machine | Medium (2) | Medium (2) | Medium (4) | New risk |
| Product | Electronic roulette used with TITO and ATRs to launder criminal funds | Medium (2) | High (3) | High (6) | No change |
| Product | Gaming machines used to launder criminal funds | Medium (2) | High (3) | High (6) | No change |
| Product | Poker - peer-to-peer gaming presents risks of collusion and the potential transfer of funds between customers | High (3) | High (3) | High (9) | No change (new wording) |
| Licensing and Integrity | Employees colluding with criminals | High (3) | High (3) | High (9) | 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 being acquired by organised crime to launder criminal proceeds or the ultimate beneficial ownership is linked to criminal activity | Low (1) | High (3) | Medium (3) | Decrease in likelihood |
Case studies
Funds originate from a cash-intensive business
A customer was identified as mixing cash they had brought to the premise with sealed packets of cash. The customer declared that their funds were from a cash-intensive business alongside additional employment, but they were not able to provide evidence of the source of funds generated through the cash intensive activity. In addition, further checks identified that the customer was in receipt of Universal Credit and Personal Independence Payments, which raised suspicion that the customer was engaged in tax and benefit fraud.
Scrutiny of source of funds
A customer provided source of funds evidence that raised suspicion as it appeared similar to a bank statement already held on file. Further scrutiny identified that the statement had been edited to falsely represent transactions and the total account balance.
References
1 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics.
2 Home Office and HM Treasury National Risk Assessment of Money Laundering and Terrorist Financing (opens in new tab) (PDF), July 2025.
2026 money laundering and risks- Casino (remote) Next section
2026 money laundering and risks - Casinos offering Money Service Businesses (MSBs)
Last updated: 30 July 2026
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