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.
3 - Gambling Commission’s risk assessment matrix (ML/TF RAM)
The Gambling Commission uses a risk matrix where the risk level is represented by a likelihood score multiplied by an impact score, in order to provide an overall risk score.
Likelihood × Impact = Risk
| Likelihood of event occurring | Impact of event occurring | Overall risk (Likelihood × Impact) |
|---|---|---|
| Low (1) | Low (1) | Low (1) |
| Low (1) | Medium (2) | Low (2) |
| Low (1) | High (3) | Medium (3) |
| Medium (2) | Low (1) | Low (2) |
| Medium (2) | Medium (2) | Medium (4) |
| Medium (2) | High (3) | High (6) |
| High (3) | Low (1) | Medium (3) |
| High (3) | Medium (2) | High (6) |
| High (3) | High (3) | High (9) |
The indicators of likelihood used in scoring refer to the potential for money laundering and terrorist financing exploitation. When considering the potential for ML or TF exploitation, various factors are taken into consideration, including:
- Commission casework and licensee compliance levels in relation to operator control vulnerabilities
- licensing controls and opportunities for staff collusion or misconduct in relation to licensing and integrity vulnerabilities
- the level of anonymity and customer demographics in relation to customer vulnerabilities
- potential links to high-risk jurisdictions in relation to geographic vulnerabilities
- product features, complexity, return to player and speed of play in relation to product vulnerabilities
- anonymity and the ability to disguise transactions in relation to means of payment vulnerabilities.
Indicators of low likelihood (score of 1) are:
- little potential for terrorist financing or money laundering exploitation
- little potential for criminal exploitation
- little or no concern based on customer and payment method anonymity
- low cost to implement anti-money laundering or counter-terrorist financing controls
Indicators of low impact (score of 1) are:
- little potential for detriment to society
- little or no impact on business environment or wider industry
- potential for minor breaches that are limited in impact and may be short term, and which are easily addressed or require very little compliance action
- impact of the risk can be dealt with by routine operations.
Indicators of medium likelihood (score of 2) are:
- some potential for terrorist financing or money laundering exploitation
- some potential for criminal exploitation
- potential concern based on customer and payment method anonymity
- standard cost to implement anti-money laundering or counter-terrorist financing controls.
Indicators of medium impact (score of 2) are:
- some potential for detriment to society
- some impact on business environment or wider industry
- potential for breaches that are more difficult or time consuming to address - may be long term or some compliance action is needed
- increased impact of the risk on operations which may subject the operator to a review of their licence.
Indicators of high likelihood (score of 3) are:
- high potential for terrorist financing or money laundering exploitation
- high potential for criminal exploitation
- heightened ML and TF concerns with the anonymous nature of customers and certain payment methods
- significant cost to implement anti-money laundering or counter-terrorist financing controls.
Indicators of high impact (score of 3) are:
- high potential for detriment to society
- heightened threat to business environment and the gambling industry
- heightened threat of serious breaches that can lead to significant penalties, fines or sanctions which will require intense compliance action
- major impact of the risk on operations - operators may face significant regulatory action
- national and/or international government inquiry or sustained adverse media coverage
Changes in risk
In order to show how the risk ratings compare to the ratings of the previous assessment, the following descriptions are used in the assessment:
New risk – this refers to identified emerging risks and previously unidentified risks that were not considered in the previous assessment.
Decrease or increase in likelihood and impact – notes a change in the risk rating.
New wording - to add more clarity and consolidate risks, the wording may have changed compared to the previous risk assessment.
Changes to the methodology
The methodology in this edition of the Gambling Commission’s risk assessment has been amended to further clarify how the potential for money laundering and terrorist financing exploitation has been considered. In addition, risk factors where controls are primarily the responsibility of the Commission through its licensing, compliance or enforcement actions and its supervisory authority role have been considered separately.
Previous sectionStages of the money laundering and terrorism financing risk assessment
Last updated: 30 July 2026
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