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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. 5 - Methodology
  3. 2 - Stages of the money laundering and terrorism financing risk assessment 

2 - Stages of the money laundering and terrorism financing risk assessment 

The risk assessment is completed in the following stages: identification, assessment and evaluation. 

Identification

In this stage, known or suspected threats and vulnerabilities are used to identify emerging risks and previously unidentified risks relating to money laundering (ML) and terrorist financing (TF) in the specific sectors within the gambling industry. Risks identified in this assessment are gathered from a variety of sources, including:

  • the gambling industry
  • research led by in-house qualified professionals
  • findings from reported data
  • intelligence
  • licensing casework
  • compliance and enforcement casework
  • media sources
  • government
  • regulatory partners
  • law enforcement agencies
  • Financial Action Task Force (FATF).

The risk assessment also takes into consideration the findings of the National Risk Assessment of Money Laundering and Terrorist Financing (the NRA)(opens in new tab)(PDF) .

Our identification of risk considers both domestic and international evidence and best practice.

Assessment and evaluation 

In this stage, an assessment of the likelihood and impact of the identified risks occurring is conducted, considering controls and consequences.  

The methodology uses an approach that can be represented as likelihood × impact = risk rating. This is conducted using the Commission’s Money Laundering and Terrorist Financing Risk Assessment Matrix (ML/TF RAM).  

In addition to considering risks at the level of individual gambling operators, we consider systemic risks in the context of the collective actions or vulnerabilities in sectors, thematic indicators or the broader industry.  

A moderation process, including reviews by qualified professionals, is utilised to evaluate the scores allocated to each risk, its likelihood of occurring and the impact should it occur. 

The Commission also considers the risks identified in the previous risk assessment and reports on their current status. The risks previously identified, and new or emerging risks identified during the time period of this assessment, are assessed using a consistent methodology.

Application of approach 

This section outlines how key concepts in the risk assessment methodology have been interpreted.  

Risk – risk is considered to be the potential that an event, action, or series of events or actions will have an adverse effect on compliance with:

Threats – threats can manifest through the intentional ‘washing’ of criminal funds, through criminal spending or by the financing of terrorism. They can relate to people seeking control of gambling businesses for illegal purposes or responsible invidivuals or businesses recklessly or unwittingly facilitating money laundering or terrorist financing through failure to discharge their responsibilities effectively. 

Vulnerabilities – the Commission has grouped the relevant factors that are assessed as vulnerabilities into 5 categories: 

  • licensee controls and vulnerabilities, including the levels of awareness and compliance with the Regulations, POCA, TACT, Money Service Business (MSB) requirements where applicable, the LCCP and Commission guidance and published learning 
  • licensing and integrity vulnerabilities  
  • customer vulnerabilities  
  • geographic vulnerabilities 
  • product vulnerabilities  
  • means of payment vulnerabilities. 

Controls – The aim of the risk assessment is to inform licensed operators about the level of risk posed to their businesses, so that they are better able to determine appropriate controls and mitigations.

The assessment of vulnerabilities requires assessment of the effectiveness of the controls in place. The absence or ineffectual application of controls, indicates a high level of vulnerability. The Commission considers controls to include:  

  • ongoing employee training
  • the design, application and review of policies, procedures and controls
  • the monitoring of their effectiveness
  • licensees acting upon identified threats and vulnerabilities to reduce the likelihood of ML/TF risks materialising.

Controls are primarily the responsibility of licensees but may also include actions taken by the Commission through its licensing, compliance or enforcement actions and its supervisory authority role.

Likelihood  – in assessing the likelihood of a threat materialising, the Commission considers:  

  • the volume, variety (from different gambling activities), speed and anonymity of monetary transactions  
  • the level of suspicious activity report (SAR) submissions by licensees to the UK Financial Intelligence Unit (UKFIU)
  • the features and complexity of products and services present within each sector 
  • each sector’s exposure to ML and TF risks
  • how the risks manifest in other gambling jurisdictions
  • instances reported to the Commission, including casework.

Impact – the impact is the extent to which the risk materialising will influence the licensing objectives and facilitate criminal or terrorist financing activity. It includes consideration of the scale of the consequences for the gambling industry and the wider economy.

Consideration of the impact also allows the Commission (as a supervisory authority) to: 

  • assess, review and monitor the effectiveness of the regulatory framework in order to minimise ML/TF in the British gambling market
  • adapt its approach to the highest risks posed by organised crime groups or individual perpetrators of money laundering and terrorist financing.
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Gambling Commission’s risk assessment matrix (ML/TF RAM) 
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