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GAMLG Annual Conference - John Pierce speech

10 June 2026

This speech was delivered by Director of Enforcement John Pierce at the Gambling Anti-Money Laundering Group (GAMLG) Annual Conference on 10 June 2026.

Please note: This is the speech as drafted and may slightly differ from the delivered version.

Hello everyone, thank you for that introduction and its great to be back again at the GAMLG annual conference. Anti-Money Laundering (AML) I think is something that we often see a lot of commentary on, a fair few panels focussed on it at conferences but it is still rare I think that you actually get productive discussion of the issues involved and how to approach protecting your customers and businesses from the risks of Money Laundering. But that’s why GAMLG is such a valuable forum for the industry in Great Britain. Each year I find there are topics of interest and led by Keith, with his breadth of experience in law enforcement, GAMLG I think provides a really important space for industry to focus on tackling Money Laundering (ML) and Terrorist Financing (TF). So thank you for inviting me back and I hope between my speech this morning and the panel later on we can have a good exchange on the issues that matter.

Today then I want to give you a snapshot on where we are. I’ll go through some useful examples of issues we’ve seen in casework and I’ll talk you through some important publications we have coming up. I will of course update you on where we are regarding the Financial Action Task Force (FATF) as we build towards the UK’s assessment. That neatly brings me on to our work with partners and other Government bodies, before finishing with a look ahead and to how the Commission wants to work with industry to support maximising the consumer offer in Great Britain.

But if we want to look ahead, we need to know where we are first. So let’s start with what we’re seeing in our casework today.

I think though it is important to note before I get into the issues we’re seeing that overall, when I look at the picture of gambling industry compliance, things have got better over the years, including in my time at the Commission since February 2024. So whilst we remain very busy in Enforcement, the cases coming through to my team, the scale of the failings that we see in casework are on the whole, less extreme. And yes, whilst the vast majority of enforcement notices you will see the Commission publish will have an element or more of AML failings in them, I think AML is part of the general improvement we have seen. And as I say this, I’m reminded of an exchange I had here last year. We were discussing how I had described remote customer relationships and transactions as higher risk for ML. The point was made to me, fairly I think, that the diligent work of so many of you in the industry and the controls you put in place go a long way to mitigating against this higher risk. And I think this is the case. So no one should take that type of description as a commentary on the efforts of what you are doing to control and mitigate risk. But we do need to see those efforts, those mitigations making an impact and keeping your businesses compliant with regulation and our rules. We want to work with you on this and I’ll come back to this point later on.

All that said, we do still see failings and we do still see issues coming up in casework that all operators should be vigilant of on their own processes and should be already dealing with if they want to avoid spending too much quality time with me and my team.

The first one I want to highlight is sadly a persistent one and one that in various ways I and others from the Commission have warned about before: too often we see a disconnect between risk assessments and policies and the procedures, and the controls put in place to carry out those policies. We do have stories in the Commission where senior executives have been surprised at how policies are carried out in practice on the ground in their businesses. This of course is no laughing matter – neither for the businesses who end up with questions to answer to my team or for the real world outcomes such failings can lead too. That we continue to see this as an issue suggests the message hasn’t got through yet so if you take anything away from this speech today, make sure you go back to your businesses and make sure your application and practice, matches the outcomes of your risk assessments and what your policies say should be happening.

And in some ways a lot of the failings we see in casework can link back to where there are links between what an operator has written down in policy and what is actually getting delivered to the consumer, whether that be through management, third party relationships and training.

So as I just mentioned, we’re seeing cases where Personal Management Licence (PML) holders do not have sufficient oversight over AML controls and have not taken appropriate steps to ensure compliance or the upholding of the licensing objectives. I think its fair to say that we have been getting tougher on PMLs at the Commission in recent years and this ought to be a wake up call to anyone with a PML to make sure you are on top of this stuff.

Further to this, we are seeing some operators not taking a risk-based approach when it comes to their internal risk assessment against money laundering and terrorist financing. That or they are not considering all risks associated with their customers and business. Either way, this is something else to check when you get back to your desks tomorrow.

Training is crucial and we know there is good practice out there in the sector. But we are seeing some significant AML failings as a result of employees not being appropriately trained in AML and not sufficiently identifying risks. This has been seen for example, where bank statements or payslips provided have shown red flags or potential fraud which has not been identified and escalated. Document checks I know, are a painful thing to make for operators, so it’s imperative that you make them count when you need to make them on AML grounds.

We’ve also seen examples of:

  • instances of gambling operators failing to conduct sufficient due diligence measures in relation to their third-party business relationships. This can include where licensees have received third party investment or entered into white label partnerships
  • cases where licensees are inadequately recording or failing to record their rationale and decision making. For example, within customer reviews, not recording the rationale for the outcome of the review and not including version controls for their policies and procedures
  • operators over-relying on financial thresholds. These are not always appropriate for the business and the customer and failing to adequately risk profile customers before they reach these financial thresholds can and does land operators in trouble.

This of course links to the work that was started on an Industry AML Code. When I spoke to you last year, I said we were happy to still work with industry on a Code but the ball was in industry’s court in terms of evidencing what was required through examples. Well as of today, the situation is broadly the same. We still need to see the evidence base as a next step.

And finally, some operators choosing to use Artificial Intelligence (AI) and algorithms for AML purposes. We aren’t ideologically against the use of new technology in your processes. But you need to be sure they are doing what is required and the evidence we’ve seen so far is too often they simply aren’t delivering. So if your business is considering this type of approach, make sure it’s delivering compliance before you launch it.

I appreciate a lot of that can sound a bit dour. But I share it to help you and in turn help you all avoid making similar failings. As I said at the start, we have seen improvements but there is more to do. Another tool we hope will be helpful to operators in staying compliant will be what we have planned for publication in the near future.

Following Government publishing their own economy wide national risk assessment of money laundering and terrorist financing last year, I said to you last year we would consider whether an update to our own risk assessment is necessary. Well as I’m sure most of you know, the writing of that risk assessment is well underway. What you may not know is that as of today, I expect it to be published in July – so just a few more weeks to wait. Like me, I’m sure you can’t wait.

The aim of the assessment is to provide a resource for the industry to use and to inform your own Money Laundering and Terrorist Financing risk assessments. The assessment will highlight risks and vulnerabilities that we have identified across the different sectors and in addition, the assessment will also consolidate risks identified in our other publications, as well as take into account the National Risk Assessment and feedback provided. Hopefully in this way it will provide a really useful guide to all of you and the wider sector on what you need to do next to prevent money laundering.

Further to this we will also be looking to publish an updated emerging risks bulletin in the Autumn, later this year.

As I said earlier, we want to work with industry to help you get this right. Whenever you have questions, we would rather hear them first than find out you’ve made mistakes later. To that end we have points of contact with the BGC and other trade bodies, we have launched the Licence Support Service earlier this year, that went live following a successful pilot in 2024. And of course the wealth of information on our website.

But our approach to working with others to deliver better outcomes extends beyond industry. We work closely with other regulators including the FCA and HMRC. We also work very closely with Government. Related to that, I’ve been asked about the Commission’s position on Treasury guidance on digital identity which redirects casinos back to the Commission for specific guidance on how this should be applied to Customer Due Diligence (CDD). Now on this, the Commission’s casino guidance will make reference to the new digital guidance. The updated casino guidance will be published after the legislative changes under The Money Laundering Regulations come into force. Using digital identity can support identity verification, but it does not remove wider responsibilities under The Money Laundering Regulations. With that in mind, Casinos should:

  • continue to assess customer risk and apply enhanced customer due diligence where appropriate
  • not assume digital identity covers all aspects of CDD: for example, understanding the purpose and intended nature of a business relationship or transaction;
  • remember they remain ultimately liable for applying CDD measures appropriately, even when using third-party services
  • ensure record keeping requirements can be met, in line with Regulation 40 of The Money Laundering Regulations.

Beyond this we are of course working with partners across Government and beyond as we prepare for the UK’s FATF assessment in 2027. We are already preparing for the assessment and this is of course not just an important test to make sure we are all living up to our responsibilities, it is also a real opportunity for ourselves and industry to make sure we are keeping our policies and processes honed and effective to the risks of money laundering today. As many of you will know, colleagues in our compliance team have already started further engagement with industry and you can expect to hear more on this as it progresses.

And clearly, whilst we want to work with all of you on strengthening AML work across the licensed sector, we continue to further develop our approach to tackling the illegal market as well. So we welcome the £26 million over three years from Treasury and are starting to put that money to good use. We welcome and are pleased to be part of the Minister-led Taskforce on illegal gambling. I personally am involved and am looking forward to how we can use it to get everyone with a role to play, pulling together. Not just regulator and industry but big tech, finance and more. And we’ll keep pushing on with our upstream interventions that last year delivered:

  • 741 Cease and Desists issued to advertisers and operators 
  • 397,527 URLs reported to various search engines and seen 266,667 URLs removed as a result so far 
  • 1,068 websites referred to the search engines for delisting 
  • 1,134 websites disrupted so that they have either been taken down or geo-blocked. 

There is plenty more to do but if we continue to pull together we can continue to make an impact.

Finally, I want to finish on a wider view of issues the Commission are looking at and what we want to be looking at in the future. On Financial Risk Assessments, as has been widely reported, the Commission’s Board did meet in May and did consider next steps. The Board was presented with an extensive evidence base but has not yet fully completed its assessment of that evidence. We know how important this is and I’m sure that’s why the Board are making sure they take the time to judge this from all sides. Whilst you are more than welcome to ask questions on this later, there really isn’t anything further to say at the moment. That said, when there is, we will update you all.

Another topic that is often brought up alongside AML is of course crypto. You will have probably also heard about how the Commission is wanting to move on this topic too. This is a topic we are considering with our Industry Forum. Following FCA progress, we are looking at what the potential path forward would be for cryptoassets to be used as a consumer payment option. We know this is an area of real interest for the licensed industry and if done in the right way could ultimately be a way of future proofing our fight against criminal activity: a strength of our AML infrastructure, as opposed to a weakness. But as you would expect me to say, this will need to be progressed in line with the licensing objectives and the money laundering regulations. So we are looking to move forwards, but this will take time.

And speaking of time, I want to make sure you have time for some questions so I’ll wrap it up there. AML is so important for both our regulatory regime and your businesses. And we want to work with you to help you get this right. So thank you for listening to me today and let’s take some questions.

Thank you.

Last updated: 10 June 2026

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