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  3. The 2026 money laundering and terrorist financing risks within the British gambling industry

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.

Published
30 July 2026

Last updated
30 July 2026 - Changes

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  1. Contents
  2. 8 - Casinos offering Money Service Businesses (MSBs)

8 - Casinos offering Money Service Businesses (MSBs)

Casinos offering services to customers including acting as a cheque casher or currency exchange, accepting winners’ cheques and foreign currency, or transmitting money are considered to be providing Money Service Business (MSB) services under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations)(opens in a new tab). Under the Regulations, the Gambling Commission is the supervisory authority for casinos in the UK and HM Revenue and Customs (HMRC) is the supervisory authority for MSBs. The Commission and HMRC have agreed, under Regulation 7(2) of the Regulations, that the Commission will act as the supervisory authority for MSB activities conducted in casinos.

All types of MSB activity carry money laundering and terrorist financing (ML/TF) risk as they could be used by criminals to break their funds up and conceal its source or destination, which makes it harder for the flow of funds to be tracked and disrupted. Foreign currency exchange activity may result in funds derived from crime in foreign countries infiltrating the UK’s financial system. MSB transactions may be one-off in nature and funds can be transferred globally.

It is noted in the National Risk Assessment of Money Laundering and Terrorist Financing (opens in new tab) (PDF) that money laundering risks associated with MSBs has not changed since the 2020 publication and remains high overall. In addition, the terrorist financing risks associated with MSBs remains high. We note that MSBs in casinos operate in different circumstances to retail MSBs, however we consider that the activity remains high risk.

MSB activity

In 2024, the Commission found that approximately 3 percent of remote casino licensees offered some form of MSB activity1. In the same period, approximately 56 percent of non-remote casino licensees also offered some form of MSB activity2. It must be noted that a licensee can operate multiple premises and not all those premises will offer MSB activity.

Commission research found that:

  • 14 casino licensees offer cheque cashing
  • 22 casino licensees offer foreign currency exchange
  • 5 casino licensees offer third party money transfer to customers’ accounts
  • 5 casino licensees offered third party money transfer from customers’ accounts.

MSB activity decreased significantly during 2022, and has remained stable at a lower level since then. The estimated value of MSB activity in casinos in 2024 was £70 million. The transactions conducted remain high value and can involve multiple currencies.

MSB risks

Customer ‘red flag’ indicators include:

  • customer conducts multiple smaller foreign currency exchange transactions to avoid reaching thresholds
  • customer transmits funds to or receives funds from a high-risk money laundering or terrorist financing jurisdiction
  • customer transactions involve significant amounts of cash in foreign currencies
  • customer buys in using a number of different payment methods
  • customer uses foreign currency exchange facilities to facilitate refining - the exchange of low denomination currency for high denomination currency
  • funds are transferred into the customer account from unknown sources 
  • customer receives payments from politically exposed persons (PEPs) or persons appearing on financial sanction lists
  • customer deposits funds in one currency and requests to withdraw in a different currency.

Operator vulnerabilities

Operator vulnerabilities in relation to MSB activity are:

  • operators with weak customer due diligence (CDD) policies and implementation of those policies, or who rely on CDD information from third parties
  • operators who demonstrate a lack of curiosity concerning customers’ source of funds
  • operators with a high turnover of staff, particularly those working in compliance teams, the Money Laundering Reporting Officer (MLRO) and staff of the MLRO’s office
  • operators who do not demonstrate a risk-based approach in their interactions and checks relating to customers
  • operators who do not appropriately consider the geographical risk of customers from high-risk jurisdictions using MSBs.

MSBs should be viewed in the context of a wide range of money laundering typologies and a constantly evolving threat picture.

HMRC provide guidance on meeting the requirements for offering MSB activity - for further information see  Money laundering: understanding risks and taking action for money service businesses (opens in new tab) and  Money service business guidance for money laundering supervision (opens in new tab).

References

1 This figure relates to casino licenses offering business to customer activity and does not include casino host licences.

2 In the period 1 January 2024 to 31 December 2024.

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