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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. 18 - Terrorist financing

18 - Terrorist financing

Sector rating

Sectors Previous overall risk rating Current overall risk rating
All sectors Medium Medium

The National Risk Assessment of Money Laundering and Terrorist Financing (the NRA) considers how funds can be generated, moved, stored and used for the purposes of terrorist financing. Casinos and gambling are considered low risk for these purposes in the NRA, although it is noted that Money Service Businesses (MSBs) may be used to move funds. Further information on terrorist financing and the financing mechanisms used can be found in the National Risk Assessment of Money Laundering and Terrorist Financing (opens in new tab) (PDF).

Risks

Vulnerability Risk Likelihood of event occurring Impact of event occurring Overall risk Change in risk
Operator control Operators failing to understand or consider terrorist financing vulnerabilities and applicable legislation Low (1) High (3) Medium (3) No change
Means of payments Cash transactions Low (1) High (3) Medium (3) No change
Means of payment Money service businesses Low (1) High (3) Medium (3) No change
Means of payment Pre-paid cards Low (1) High (3) Medium (3) No change
Means of payment E-wallets Low (1) High (3) Medium (3) No change
Means of payment Cryptoasset transactions Low (1) High (3) Medium (3) No change
Licensing and Integrity Charities with society lottery licences being used to generate funds for a proscribed organisation Low (1) High (3) Medium (3) No change (new wording)

Terrorism 'red flag' indicators

Some potential ‘red flag’ indicators that operators should be aware of are:

  • customer bank statements display suspicious activity. For example, where it is not possible to verify the origin of the funds, or where funds are sent to or received from higher-risk locations
  • customers from higher-risk jurisdictions spending large amounts of cash
  • unusual numbers of cards or payment types being used on one account
  • smurfing – placing frequent smaller bets across different betting accounts
  • withdrawals from an account are not commensurate with the conduct of the account, such as for instance where the player makes numerous withdrawals without engaging in significant gambling activity
  • a customer’s income or expenditure which is inconsistent with their employment
  • unusual or suspicious religious quotes, or single words or phrases relating to known terrorist ideology or numerical associations to terrorism in financial transactions and customer details (social media ‘handle’, web chat, email addresses, and so on)
  • MSB usage, including indicators such as multiple overseas geographical locations destination for transfers, use of third parties in the transaction chain, open loop for foreign exchange transactions, that is, deposits in one currency and requests to withdraw in a different currency and missing details on money transfers
  • customer use of pre-paid cards
  • customer IP address is linked to multiple accounts
  • use, or attempted use, of fraudulent documentation such as fake identity documents that don’t belong to the individual presenting the document
  • suspicious activity in peer-to-peer gaming, where the customer appears to make deliberate loses.

Case study

Links to a proscribed organisation
When an operator conducted open-source checks on a customer, they identified that the customer had reported links to a proscribed organisation and the customer’s source of funds could not be verified. A proscribed organisation is an organisation or group that is illegal to join or show support for because it has been identified as being involved in terrorism1. Due to the concerns identified, there was a risk that the winnings generated may be transferred to the proscribed organisation.

References

1The Home Office publishes the list of proscribed organisations (opens in new tab) .

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2026 money laundering and risks - Gaming machine technical (remote and non-remote) Next section
2026 money laundering and risks - Proliferation financing
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