Emerging money laundering and terrorist financing risks from October 2025
Licence Condition 12.1.1(3) of the Licence Conditions and Codes of Practice (LCCP), requires operators to keep up-to-date with emerging risks information published by the Gambling Commission.
This emerging risks publication is a trigger for operators to review their money laundering and terrorist financing risk assessments and related policies, procedures and controls to ensure that they remain appropriate and effective.
Pre-paid payment methods
Risk information
The emerging risks bulletins published in April 2020 and February 2022, highlighted the money laundering and terrorist financing (MLTF) risks associated with pre-paid cards. The Commission’s 2023 MLTF risk assessment also classified pre-paid cards as high-risk payment methods.
In addition to pre-paid cards being classified as high-risk, the Commission also views pre-paid vouchers and all other pre-paid payment methods as high-risk.
Pre-paid payment methods are considered high-risk by the Commission due to a variety of factors, including: the ability to pre-pay or pre-load using cash and, in some cases, cryptoassets either directly or via third party websites; the anonymous nature of some pre-paid payment methods; the ability with some methods to pre-pay using credit cards; the lack of traceability and the open-loop nature of many pre-paid methods which do not allow deposits back onto the card or voucher.
What operators need to do
All payment methods, including pre-paid cards and pre-paid vouchers, need to be considered in an operator’s risk assessment, as per Licence Condition (LCCP) 12.1.1(1). The Commission’s expectation is that these will be treated as high risk in accordance with the Commission’s risk assessment.
The use of pre-paid payment methods needs to be factored into a customer’s risk profile and appropriate risk-based due diligence must then be conducted by the operator. Where a customer is assessed as presenting a higher risk, additional information in respect of that customer should be collected. The additional information should include an understanding of where the customer’s funds and wealth have come from. The need to 'know your customer' (KYC) checks are particularly relevant here.
Operators are also reminded that it is mandatory to submit a key event to the Commission under Licence Condition 15.2.1(8) where there are any changes to the methods by which, and/or the payment processors through which, the licensee accepts payment from customers using their gambling facilities. When notifying the Commission under this Licence Condition, we expect the following information to be provided as a minimum:
- the type of payment method
- the provider
- how the payment method was assessed in the operator’s money laundering and terrorist financing risk assessment.
Gambling businesses are ultimately responsible for ensuring sufficient customer checks are carried out and must not rely on third party payment processors to conduct ‘KYC’ checks on their behalf or rely on third parties to establish source of funds without further scrutiny.
Licensees are reminded that under Licence Condition 6.1.2 (1) they must not accept payment for gambling by credit card. This includes payments to the licensee made by credit card through a money service business. Where pre-paid methods are accepted, licensees are expected to ensure that this is not a route to circumvent the restrictions on the use of credit cards for the purposes of gambling.
Licensees must ensure that their policies, procedures and controls are implemented effectively, kept under review, revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time (as required under Licence Condition 12.1.1.(3)).
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Emerging money laundering and terrorist financing risks from April 2025
Last updated: 2 October 2025
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