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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. 19 - Proliferation financing

19 - Proliferation financing

Proliferation financing (PF) is defined as:

The act of providing funds or financial services for use (in whole or in part) in the manufacture, acquisition, development, export, trans-shipment, brokering, transport, transfer, stockpiling of, or otherwise in connection with the possession or use of chemical, biological, radiological or nuclear weapons, including the provision of funds or financial services in connection with the means of delivery of such weapons and other CBRN-related goods and technology1, in contravention of a relevant financial sanctions obligation2.

HM Treasury’s National Risk Assessment of Proliferation Financing (opens in new tab) (PDF) does not specifically give a rating for the level of PF risk in casinos or the wider gambling sector. It does however note that the awareness of PF risk in Designated Non-Financial Businesses and Professions (DNFBPs) is in general low3.

Proliferation financing risk must be considered by casinos in line with the requirements of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in new tab). When compiling their PF risk assessments, casino operators must take into account HM Treasury’s national PF risk assessment. We encourage all operators to consider how their business may be exposed to PF risk, including through customers and business-to-business relationships.

Some examples of proliferation financing ‘red flag’ indicators are:

  • customers associated with casino junket tours where appropriate customer due diligence and enhanced customer due diligence cannot be completed
  • use or attempted use of fraudulent documentation such as fake identity documents
  • unusual numbers of cards or payment types being used on one account
  • a customer IP address that is linked to multiple accounts
  • suspicious activity in peer-to-peer gaming where the customer appears to make deliberate losses
  • source of funds or wealth checks identify that customer funds are from the trade of ‘dual use goods’ with sanctioned states4
  • customer source of funds is cryptoassets which have previously passed through a mixer5
  • customer is associated with a sanctioned state or individual.

Case study

It was identified that the Democratic People's Republic of Korea (DPRK) has generated revenue from the development and sale of online gambling websites, as well as a variety of IT development work6. To mitigate this risk, appropriate due diligence should be conducted on third-party business relationships.

References

1The meaning of “biological weapon”, “chemical weapon”, “CBRN-related goods and technology”, “nuclear weapon” and “radiological weapon” are set out in regulation 16A(10).

2A relevant financial sanctions obligation is a prohibition or requirement in regulations made under section 1 of the Sanctions and Anti-Money Laundering Act 2018 and imposed for one or more of the purposes in section 3(1) and (2) of the Act so far as it relates to compliance with a relevant UN obligation.

3HM Treasury, ‘National Risk Assessment of Proliferation Financing’ (opens in new tab) (PDF), September 2021.

4 The ‘National Risk Assessment of Proliferation Financing’ defines dual use items as “goods, software, technology, documents and diagrams which can be used for both civil and military applications. They can range from raw materials to components and complete systems, such as aluminium alloys, bearings, or lasers. They could also be items used in the production or development of military goods, such as machine tools, chemical manufacturing equipment and computers.”

5A crypto mixer is a service that increases transaction privacy by pooling and redistributing cryptoassets to obscure the link between sender and recipient addresses.

6Royal United Services Institute (RUSI), “North Korean Activity in the Casino and Gaming Sector: How Do Jurisdictions Respond?” (opens in new tab) (PDF), September 2024.

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2026 money laundering and risks - Illegal markets
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