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.
13 - Gambling software (remote and non-remote)
Sector rating
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Gambling software (remote and non-remote) | Low | Medium |
The gambling software sector has increased from low to medium risk for money laundering.
This is due to the risk posed by business-to-business relationships and the risk of licensed operators supplying software to illegal website operators. For further information on this risk, refer to the section on illegal markets.
The sale of software to illegal website operators may not be by a licensed operator directly but may result from insufficient monitoring of third-party contracts and activity. As software supply can involve cross-border arrangements with multiple parties, there is a greater potential for money laundering exploitation.
Gambling software businesses may also receive funds in the form of cryptoassets or from businesses offering cryptoasset activity. This has been noted as occurring through business relationships and investments.
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 | Low (1) | Medium (2) | Low (2) | Increase in impact | Operator control | Inadequate due diligence checks on third party business relationships - including business-to-business customers and test houses. | Medium (2) | High (3) | High (6) | Increase in impact and likelihood (new wording) | Operator control | Inadequate due diligence checks on business investors | Medium (2) | Medium (2) | Medium (4) | Increase in likelihood (new wording) | Operator control | Insufficient monitoring of third-party contracts to identify the resale of software to unlicensed sites | Medium (2) | Medium (2) | Medium (4) | New risk | Means of payment | Cryptoasset transactions | Medium (2) | High (3) | High (6) | New risk | Geographic | B2B partner is based in or linked to a high-risk jurisdiction | Medium (2) | Medium (2) | Medium (4) | New risk |
Commission-controlled risks
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations run or acquired by organised criminals to launder criminally-derived funds | Low (1) | Medium (2) | Low (2) | New risk |
Case studies
Business investors
A gambling software company received a loan where the ultimate source of funds was revenue from a remote casino offering cryptoasset facilities. The Commission identified that the due diligence checks conducted on the remote casino were insufficient. Further investigation showed that the casino was encouraging circumvention of geo-blocking controls by customers by describing how this can be achieved.
A business applying for a licence had obtained funding through an Initial Coin Offering (ICO), which is a fundraising method where a project sells cryptoasset tokens to investors. The majority of the funds used to buy the tokens were from cryptoassets, such as Bitcoin, Ethereum and Tether. The business’ due diligence checks on the ICO investors were insufficient as source of funds checks had not been completed and, in some cases, the identity documents collected could not be linked to the list of ICO investors. Additionally, the due diligence checks completed on other business investors were insufficient. The Commission identified that one investor had been convicted for a money laundering offence.
Software supply to illegal sites
The games used by a licensed operator appeared on an unlicensed gambling website as a result of the software reseller entering into an agreement with the operator of the unlicensed gambling website. Software businesses may be at risk of accepting proceeds of crime generated by illegal gambling activity through third party arrangements.
2026 money laundering and risks - Bingo (non-remote) Next section
2026 money laundering and risks - Arcades
Last updated: 30 July 2026
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