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.
1 - Executive summary
The Gambling Commission’s Money Laundering (ML) and Terrorist Financing (TF) risk assessment 2026 presents the key ML and TF risks associated with licensed gambling in Great Britain. The risk landscape faced by licensed gambling operators continues to evolve. Technology-driven advancements in particular pose new challenges, such as the rapid development in artificial intelligence capability which tests the effectiveness of customer due diligence controls. The growth of illegal gambling websites also exposes operators to illicit financial flows in their business-to-business relationships. Consequently, this assessment provides an overview of the risks posed to different gambling businesses, including opportunities for ML and TF exploitation by illicit actors, as well as vulnerabilities in compliance frameworks.
This risk assessment covers all licensed non-remote and remote gambling activity in the British gambling industry. It builds on the 2023 risk assessment and, among other things, fulfils the supervisory requirements under Regulation 17(1) of the Money Laundering and Terrorist Financing and Transfer of Funds (Information on the Payer) 2017 (the Regulations)(opens in new tab).
The purpose of this risk assessment is to:
- provide a resource for the industry to inform their own ML and TF risk assessments
- provide support to the National Risk Assessment of Money Laundering and Terrorist Financing conducted by HM Treasury and the Home Office
- inform and prioritise our licensing, compliance and enforcement activity in order to raise standards in the industry, and to meet our duties under regulation 46(2)(c) of the Regulations which is to base the frequency and intensity of our on-site and off-site supervision on the risk profiles prepared under regulation 17(4)) (opens new tab).
The Commission has considered a wealth of information and intelligence when assessing the key threats identified within the British gambling industry and provides revised risk ratings in this publication. The risk assessment has been developed in consultation with in-house and external subject-matter experts, with input from a wide range of sector and industry specialists, including law enforcement and the National Crime Agency (the NCA). Approaches taken by other anti-money laundering (AML) supervisory authorities were also considered.
Risks for the period 1 April 2023 to 31 October 2025 have been examined. The methodology used to assess the risks in Britain’s gambling industry has not altered from that used in 2023. To add more clarity and consolidate risks, there are changes in the wording used to describe risks. For more detail on the methodology and terminology used, please refer to the methodology section of this report.
The overall risk ratings for each sector are as follows:
| Sector | Overall risk rating |
|---|---|
| Casino, betting and bingo (remote) | High |
| Casino (non-remote) | High |
| Betting (non-remote, off-course) | High |
| Betting (non-remote, on-course) | Medium |
| Bingo (non-remote) | Medium |
| Gambling software (remote and non-remote) | Medium |
| Adult Gaming Centres (AGCs) | Medium |
| Family Entertainment Centres (FECs) | Low |
| Society lotteries and external lottery managers (remote and non-remote) | Low |
| The National Lottery (remote and non-remote) | Low |
| Gaming machine technical (remote and non-remote) | Low |
HM Treasury and the Home Office are responsible for conducting a risk assessment of key money laundering and terrorist financing risks for the United Kingdom. In the National Risk Assessment of Money Laundering and Terrorist Financing (the NRA)(pdf)(opens in new tab), the casino sector risk rating has increased to medium. This was driven by changes in customer, geographical and transaction risks since 2020, particularly an increase in funds moving through remote casinos, new ways to play casino games, the updated assessment of money service business (MSB) activities offered by some casinos and the increased presence of illegal casinos targeting British consumers.
The NRA captures the relative risk of ML and TF occurring across all regulated financial sectors and Designated Non-Financial Businesses and Professionals (DNFBPs), which includes retail banking, money services businesses, legal service providers, accountancy services and cryptoasset businesses.
When the vulnerability of gambling to ML and TF is considered in the NRA, the casino sector is currently rated medium risk relative to other regulated sectors. The NRA does not provide an overall rating of other gambling sectors. By contrast, the Commission’s risk assessment compares the ML and TF risks in individual gambling sub-sectors and rates them in comparison to each other, either high, medium or low risk, rather than in comparison to other regulated sectors.
When compiling the NRA, HM Treasury and the Home Office are required to ensure that the risk assessment is used to consider whether providers of gambling services other than casinos should continue to be excluded from the requirements of the Regulations. It is therefore imperative that the Commission and gambling operators sustain their efforts and remain on guard to the financial crime risks inherent in gambling.
The overall risk ratings for gambling sectors have remained the same as previous years, with the exception of gambling software which has increased from low to medium risk. For further information, please see the Gambling software section of this document.
| Risk | Overall risk rating |
|---|---|
| Terrorist financing | Medium |
While the NRA categorises the casino sector as a low risk for terrorist financing (TF), the Gambling Commission elevates the sector's overarching rating to medium risk. The difference in rating is a result of the methodologies used. Both assessments agree that the likelihood of TF activity remains low. However, the Commission’s framework factors in the severe impact of a potential TF event, lifting the combined rating to medium. For further information, please refer to the methodology section of this assessment.
The Commission has also collaborated closely with external stakeholders to assist in our understanding of the terrorist financing typologies and vulnerabilities that are applicable to the gambling industry when arriving at the risk rating.
This document is intended to act as a valuable resource for the industry to inform their own ML and TF risk assessments. It must also be taken into account when operators conduct their risk assessments, as required under Licence Condition 12 of the Licence Conditions and Codes of Practice (LCCP)1.
Casinos (both non-remote and remote) have additional legal responsibilities, as they must comply with the Regulations for casino gaming, gaming machines and any money service business activities they offer2.
However, it is imperative for all gambling operators (regardless of gambling sector) to ensure that they have effective risk assessments identifying ML and TF risks, and robust policies, procedures and controls to prevent money laundering and terrorist financing, and to continue to raise standards in these areas.
References
1 Licence Condition 12 requires that operators have appropriate policies, procedures and controls to prevent money laundering and terrorist financing and that such policies, procedures and controls take into account any applicable learning or guidelines published by the Gambling Commission.
2 This refers to the Regulations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in new tab) ('the Regulations') which are applicable to firms under the 'regulated sector'. Casinos are part of the 'regulated sector'.
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2026 money laundering and risks - Introduction
Last updated: 30 July 2026
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