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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
This version was printed or saved on: 30 July 2026
Online version: https://www.gamblingcommission.gov.uk/guidance/the-2026-money-laundering-and-terrorist-financing-risks-within-the-british-gambling-industry
The Gambling Commission’s Money Laundering (ML) and Terrorist Financing (TF) risk assessment 2026 presents the key ML and TF risks associated with licensed gambling in Great Britain. The risk landscape faced by licensed gambling operators continues to evolve. Technology-driven advancements in particular pose new challenges, such as the rapid development in artificial intelligence capability which tests the effectiveness of customer due diligence controls. The growth of illegal gambling websites also exposes operators to illicit financial flows in their business-to-business relationships. Consequently, this assessment provides an overview of the risks posed to different gambling businesses, including opportunities for ML and TF exploitation by illicit actors, as well as vulnerabilities in compliance frameworks.
This risk assessment covers all licensed non-remote and remote gambling activity in the British gambling industry. It builds on the 2023 risk assessment and, among other things, fulfils the supervisory requirements under Regulation 17(1) of the Money Laundering and Terrorist Financing and Transfer of Funds (Information on the Payer) 2017 (the Regulations)(opens in new tab).
The purpose of this risk assessment is to:
The Commission has considered a wealth of information and intelligence when assessing the key threats identified within the British gambling industry and provides revised risk ratings in this publication. The risk assessment has been developed in consultation with in-house and external subject-matter experts, with input from a wide range of sector and industry specialists, including law enforcement and the National Crime Agency (the NCA). Approaches taken by other anti-money laundering (AML) supervisory authorities were also considered.
Risks for the period 1 April 2023 to 31 October 2025 have been examined. The methodology used to assess the risks in Britain’s gambling industry has not altered from that used in 2023. To add more clarity and consolidate risks, there are changes in the wording used to describe risks. For more detail on the methodology and terminology used, please refer to the methodology section of this report.
The overall risk ratings for each sector are as follows:
| Sector | Overall risk rating |
|---|---|
| Casino, betting and bingo (remote) | High |
| Casino (non-remote) | High |
| Betting (non-remote, off-course) | High |
| Betting (non-remote, on-course) | Medium |
| Bingo (non-remote) | Medium |
| Gambling software (remote and non-remote) | Medium |
| Adult Gaming Centres (AGCs) | Medium |
| Family Entertainment Centres (FECs) | Low |
| Society lotteries and external lottery managers (remote and non-remote) | Low |
| The National Lottery (remote and non-remote) | Low |
| Gaming machine technical (remote and non-remote) | Low |
HM Treasury and the Home Office are responsible for conducting a risk assessment of key money laundering and terrorist financing risks for the United Kingdom. In the National Risk Assessment of Money Laundering and Terrorist Financing (the NRA)(pdf)(opens in new tab), the casino sector risk rating has increased to medium. This was driven by changes in customer, geographical and transaction risks since 2020, particularly an increase in funds moving through remote casinos, new ways to play casino games, the updated assessment of money service business (MSB) activities offered by some casinos and the increased presence of illegal casinos targeting British consumers.
The NRA captures the relative risk of ML and TF occurring across all regulated financial sectors and Designated Non-Financial Businesses and Professionals (DNFBPs), which includes retail banking, money services businesses, legal service providers, accountancy services and cryptoasset businesses.
When the vulnerability of gambling to ML and TF is considered in the NRA, the casino sector is currently rated medium risk relative to other regulated sectors. The NRA does not provide an overall rating of other gambling sectors. By contrast, the Commission’s risk assessment compares the ML and TF risks in individual gambling sub-sectors and rates them in comparison to each other, either high, medium or low risk, rather than in comparison to other regulated sectors.
When compiling the NRA, HM Treasury and the Home Office are required to ensure that the risk assessment is used to consider whether providers of gambling services other than casinos should continue to be excluded from the requirements of the Regulations. It is therefore imperative that the Commission and gambling operators sustain their efforts and remain on guard to the financial crime risks inherent in gambling.
The overall risk ratings for gambling sectors have remained the same as previous years, with the exception of gambling software which has increased from low to medium risk. For further information, please see the Gambling software section of this document.
| Risk | Overall risk rating |
|---|---|
| Terrorist financing | Medium |
While the NRA categorises the casino sector as a low risk for terrorist financing (TF), the Gambling Commission elevates the sector's overarching rating to medium risk. The difference in rating is a result of the methodologies used. Both assessments agree that the likelihood of TF activity remains low. However, the Commission’s framework factors in the severe impact of a potential TF event, lifting the combined rating to medium. For further information, please refer to the methodology section of this assessment.
The Commission has also collaborated closely with external stakeholders to assist in our understanding of the terrorist financing typologies and vulnerabilities that are applicable to the gambling industry when arriving at the risk rating.
This document is intended to act as a valuable resource for the industry to inform their own ML and TF risk assessments. It must also be taken into account when operators conduct their risk assessments, as required under Licence Condition 12 of the Licence Conditions and Codes of Practice (LCCP)1.
Casinos (both non-remote and remote) have additional legal responsibilities, as they must comply with the Regulations for casino gaming, gaming machines and any money service business activities they offer2.
However, it is imperative for all gambling operators (regardless of gambling sector) to ensure that they have effective risk assessments identifying ML and TF risks, and robust policies, procedures and controls to prevent money laundering and terrorist financing, and to continue to raise standards in these areas.
1 Licence Condition 12 requires that operators have appropriate policies, procedures and controls to prevent money laundering and terrorist financing and that such policies, procedures and controls take into account any applicable learning or guidelines published by the Gambling Commission.
2 This refers to the Regulations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in new tab) ('the Regulations') which are applicable to firms under the 'regulated sector'. Casinos are part of the 'regulated sector'.
The Gambling Commission (the Commission) is the supervisory authority for casinos under the Money Laundering and Terrorist Financing and Transfer of Funds (Information on the Payer) 2017 (the Regulations) (opens in new tab) and therefore has an obligation under Regulation 17 to carry out a risk assessment of casinos, which this assessment satisfies.
The Commission also uses this risk assessment to inform HM Government of the level of risk of money laundering (ML) and terrorist financing (TF) within the British gambling industry. A sector may become higher risk over time, due to changing vulnerabilities or the attributes of the sector. If a gambling sector’s risk increases, HM Treasury may consider whether the sector needs to be subject to the provisions of the Regulations.
A risk assessment is a key requirement to understanding the ML and TF risks that a business is exposed to. This is done through the identification, assessment, management, control and, where possible, the mitigation of risks to prevent ML and TF. By knowing and understanding the risks to which the gambling industry is exposed, HM Government, law enforcement, the Commission and gambling operators can work together to ensure that gambling in Great Britain is a hostile place for money launderers and terrorist financers seeking to exploit it.
This risk assessment builds upon our understanding of the risks identified in our previous published risk assessments, namely the:
The money laundering (ML) and terrorist financing (TF) threats that the gambling industry faces are diverse, complex and rapidly evolving. There is a need to respond to rapid changes in the use of technology, as well as managing the risks of innovative payment methods. These include advancements in artificial intelligence (AI) and the evolution of high-velocity digital payment systems (such as those involving cryptoassets), fake identities generated using AI, and altered identification documents. This makes it difficult to detect sophisticated transaction structuring and advanced automation. The Gambling Commission has set out its approach to AI on its website.
The National Risk Assessment of Money Laundering and Terrorist Financing (the NRA)(opens in new tab)(PDF) notes that the most common occurrences of ML through licensed casinos are in the form of recreational spending of criminal property, however there are also instances of attempts by criminals to ‘clean’ illicit funds through casinos.
Money launderers and terrorist financers use similar methods to store, move and obtain funds, although their motives may differ.
It is important that the Commission and gambling operators remain on guard to the financial crime risks inherent in gambling, and work to mitigate ML and TF risks.
If left unimpeded, there is the potential for:
Gambling operators must ensure they comply with the relevant legislation, and the regulatory licence conditions and codes of practice. These are:
Further information can be found within our anti-money laundering (AML) legislation page.
It is mandatory for all gambling operators to comply with the licensing objective of keeping crime and its proceeds out of gambling, as set out in The Gambling Act 2005 (the Act) (opens new tab) and the LCCP.
Furthermore, all gambling operators have legal duties under the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000 (TACT) (opens in a new tab) to mitigate financial crime.
Operators are required to adopt a risk-based approach tailored to their own business model in discharging their legal obligations, which focuses compliance effort where it is most needed and will therefore have the most impact. It requires the full commitment and support of senior management and the active co-operation of all employees.
For further information regarding the steps gambling operators should take in applying a risk-based approach, please see our guidance on the prevention of money laundering and combating the financing of terrorism (casino operators) and our guidance on duties and responsibilities under the Proceeds of Crime Act 2002 (all other operators).
In line with Licence Condition 12.1.1, gambling operators are required to have AML and counter-terrorist financing (CTF) policies, procedures and controls in place and ensure that they 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 Commission from time to time.
The Regulations also require casino operators to risk assess and mitigate proliferation financing. Proliferation financing 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 Chemical, Biological, Radiological and Nuclear (CBRN)-related goods and technology1, in contravention of a relevant financial sanctions obligation2."
For further information on what casinos are required to do in relation to proliferation financing, please refer to the Commission’s casino guidance.
Gambling operators are also required to comply with financial sanctions legislation. For further information on how to comply with the sanctions requirements, please refer to the Office of Financial Sanctions Implementation guidance (opens in new tab).
1 The meaning of 'biological weapon', 'chemical weapon', 'CBRN-related goods and technology', 'nuclear weapon' and 'radiological weapon' are set out in regulation 16A(10).
2 A relevant financial sanctions obligation is a prohibition or requirement in regulations made under section 1 of the Sanctions and Anti-Money Laundering Act 2018 (opens in new tab) 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 United Nations (UN) obligation.
The risk assessment considers evidence gathered for the period 1 April 2023 to 31 October 2025.
The Gambling Commission (the Commission) has adopted a risk assessment methodology based on the Financial Action Task Force (FATF) Guidance on Money Laundering and Terrorist Financing Risk Assessments. FATF sets the global standards for anti-money laundering, counter-terrorist financing and proliferation financing1.
It is important to note that the Commission’s assessment of risk within each sector or theme is considered in the context of the British gambling industry and not in comparison to other British industries regulated under the Money Laundering Regulations, for example, the retail banking sector2. Furthermore, the Commission may not have access to the confidential source materials available to HM Treasury and the Home Office when they produce the National Risk Assessment of Money Laundering and Terrorist Financing. Our risk assessment considers the data and information we hold or have access to, specialist knowledge and sources that are available externally.
1 FATF Guidance “National Money Laundering and Terrorist Financing Risk Assessment” February 2013.
2 The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
The risk assessment is completed in the following stages: identification, assessment and evaluation.
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 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.
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.
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:
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:
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:
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:
The Gambling Commission uses a risk matrix where the risk level is represented by a likelihood score multiplied by an impact score, in order to provide an overall risk score.
| Likelihood of event occurring | Impact of event occurring | Overall risk (Likelihood × Impact) |
|---|---|---|
| Low (1) | Low (1) | Low (1) |
| Low (1) | Medium (2) | Low (2) |
| Low (1) | High (3) | Medium (3) |
| Medium (2) | Low (1) | Low (2) |
| Medium (2) | Medium (2) | Medium (4) |
| Medium (2) | High (3) | High (6) |
| High (3) | Low (1) | Medium (3) |
| High (3) | Medium (2) | High (6) |
| High (3) | High (3) | High (9) |
The indicators of likelihood used in scoring refer to the potential for money laundering and terrorist financing exploitation. When considering the potential for ML or TF exploitation, various factors are taken into consideration, including:
Indicators of low likelihood (score of 1) are:
Indicators of low impact (score of 1) are:
Indicators of medium likelihood (score of 2) are:
Indicators of medium impact (score of 2) are:
Indicators of high likelihood (score of 3) are:
Indicators of high impact (score of 3) are:
In order to show how the risk ratings compare to the ratings of the previous assessment, the following descriptions are used in the assessment:
New risk – this refers to identified emerging risks and previously unidentified risks that were not considered in the previous assessment.
Decrease or increase in likelihood and impact – notes a change in the risk rating.
New wording - to add more clarity and consolidate risks, the wording may have changed compared to the previous risk assessment.
The methodology in this edition of the Gambling Commission’s risk assessment has been amended to further clarify how the potential for money laundering and terrorist financing exploitation has been considered. In addition, risk factors where controls are primarily the responsibility of the Commission through its licensing, compliance or enforcement actions and its supervisory authority role have been considered separately.
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Casino (remote) | High | High |
The remote casino sector continues to be rated as high risk for money laundering.
Casino products with higher return to player ratios are at risk of being exploited for money laundering purposes, and peer-to-peer activity in poker carries higher ML and TF risk as it can facilitate the exchange of criminal funds between customers.
Remote casinos also have a high level of transactions. The gross gambling yield (GGY) for the sector in the period April 2024 to March 2025 was £5.0 billion, £4.2 billion of which was from slot games1.
The remote sector faces challenges as a result of customers not being present for verification purposes. This includes the use of fraudulent documentation to bypass customer due diligence (CDD) controls, as well as the risk of mule accounts being created. Developments in artificial intelligence (AI) tools create further challenges. The Gambling Commission is aware of an increase in the scale and sophistication of attempts to bypass CDD checks using false documentation, deepfake videos and face swaps generated by AI.
The remote sector is also exposed to financial flows from higher risk payment methods, including e-wallets, pre-paid methods and the presence of funds linked to cryptoassets. Further risks can be present when customers use multiple methods of payment, or an open-loop system is in operation.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | High (3) | High (3) | High (9) | No change |
| Operator control | Lack of competence of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | High (3) | High (6) | No change |
| Operator control | Lack of adequate and relevant due diligence checks on customers who are not physically present for verification purposes | High (3) | High (3) | High (9) | New risk |
| Operator control | Lack of appropriate customer risk profiling and ongoing monitoring | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Inappropriate AML thresholds - including thresholds that are not appropriate for the customer base or are predominantly loss based | High (3) | High (3) | High (9) | No change (new wording) |
| Operator control | High value customer schemes | Low (1) | High (3) | Medium (3) | Decrease in likelihood |
| Operator control | Lack of closed-loop system | Medium (2) | High (3) | High (6) | No change |
| Operator control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) | New risk |
| Operator control | Inappropriate controls relating to linked or duplicate accounts - this includes identifying linked accounts and, where multiple accounts are permitted, applying controls across accounts | High (3) | High (3) | High (9) | New risk |
| Operator control | Inadequate due diligence on white label partnerships | High(3) | High (3) | High (9) | No change (new wording) |
| Operator control | Inadequate due diligence checks on business-to-business relationships or business investors, resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds - this includes the use of AI tools to generate documents or videos | High (3) | High (3) | High (9) | No change (new wording) |
| Customer | Customer gambles with multiple remote operators to disguise the source of their funds | Medium (2) | High (3) | High (6) | Decrease in likelihood (new wording) |
| Customer | Customers who appear on financial sanctions lists laundering funds which are subject to an asset freeze | Low (1) | High (3) | Medium (3) | No change |
| Customer | Foreign politically exposed persons (PEPs) using casinos to launder criminal funds | Medium (2) | High (3) | High (6) | No change |
| Customer | Domestic PEPs using casinos to launder criminal funds | Low (1) | Medium (2) | Low (2) | No change |
| Customer | Customers making numerous low-level transactions to minimise suspicion and evade CDD requirements at the threshold (‘smurfing’) | Medium (2) | High (3) | High (6) | Decrease in likelihood |
| Customer | Third party use of customer accounts to obscure the source of funds and identity of the user, including the creation of mule accounts and the use of agents | High (3) | High (3) | High (9) | No change (new wording) |
| Customer | Customer linked to criminal activity | High (3) | High (3) | High (9) | New risk |
| Customer | Customer presents risks relating to their source of income - including access to third-party funds or funds originating from a cash intensive business | Medium (2) | Medium (2) | Medium (4) | New risk |
| Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer uses a third-party payment method that is not in their name | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer displays suspicious or unusual wagering patterns - such as withdrawing after minimal play | High (3) | High (3) | High (9) | New risk |
| Geographic | Customers who are a resident of or are linked to high-risk jurisdictions using casino facilities to launder criminal funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Means of payment | Pre-paid methods including vouchers and cards - this payment method can make it difficult to identify the source of funds | Medium (2) | High (3) | High (6) | Decrease in likelihood |
| Means of payment | E-wallets - this payment method can make it difficult to identify the source of funds | Medium (2) | Medium (2) | Medium (4) | No change |
| Means of payment | Crypto asset transactions | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Multiple methods of payment | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Casinos acting as Money Service Businesses (MSBs) | High (3) | High (3) | High (9) | New risk |
| Product | Poker - peer-to-peer gaming presents risks of collusion and the potential transfer of funds between customers | High (3) | High (3) | High (9) | No change (new wording) |
| Product | High-stakes gambling on live casino games | Medium (2) | High (3) | High (6) | No change (new wording) |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations being acquired by organised crime to launder criminal proceeds or the ultimate beneficial ownership is linked to criminal activity | Low (1) | High (3) | Medium (3) | No change |
Multiple accounts and false or stolen identity documents
A customer deposited approximately £40,000 over the course of 6 months, creating accounts using the details of 5 different individuals.
Circumvention of identity verification controls
A customer, whose account had previously been blocked due to suspicion of money laundering, was able to circumvent identity verification checks at sign-up and create a new account. Operator controls were insufficient to identify small discrepancies within customer sign up data fields.
Mule accounts and scrutiny of source of funds
A group of students were suspected of money mule activity. The operator’s controls identified that the students displayed similar wagering patterns with high returns. The operator’s subsequent investigations identified that the students had signed up on similar dates and their source of funds appeared to be the same.
An 18-year-old customer was suspected of gambling on behalf of third parties. A review of the customer’s source of funds information showed that they were gambling with multiple operators, their activity was funded by third parties, and their level of activity appeared disproportionate to their declared employment.
Customer linked to a high-risk jurisdiction
A customer was flagged for suspicious betting patterns and triggered enhanced customer due diligence controls. When asked to provide source of funds evidence, the customer advised this was not possible as their source of funds was cash brought to the UK from their home in a high-risk jurisdiction.
Pre-paid payment method
A customer made large deposits using a pre-paid card, and their gaming activity raised suspicion due to minimal wagering. The customer then proceeded to request withdrawals to different bank accounts. The risk in this case is that the customer may have been exploiting pre-paid methods, alongside open-loop systems, to move large volumes of funds while disguising their origin.
1 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics.
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Casino (non-remote) | High | High |
The non-remote casino sector continues to be rated as high risk for money laundering.
The casino environment allows high stakes wagering, as well as products vulnerable to collusion. Peer-to-peer activity, such as poker, can also be exploited to facilitate the exchange of funds between customers and so carries a higher ML and TF risk.
The level of activity in non-remote casinos has increased since the previous risk assessment. In the period April 2022 to March 2023, gross gambling yield (GGY) in the sector was £810 million and, in April 2024 to March 2025, it rose to £934 million. However, the overall level of funds moving in the sector has not returned to its pre-COVID pandemic levels1.
The non-remote sector faces challenges of applying effective controls in the live environment of the premises. For example, where casinos allow customers to enter without formal identification, they need to determine how to ensure customers’ identities are verified and customers are actively monitored in line with the requirements of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations) (opens in new tab).
The National Risk Assessment of Money Laundering and Terrorist Financing (opens in new tab) (PDF) (the NRA) identified the casino sector as having a high risk of exposure to cash and noted that, while the use of cash for legitimate transactions has declined, it remains widely used by criminals2. Risks are also posed by other payment methods available in casinos, for example where a customer deposits using a terminal and there is potentially less oversight than funds deposited at a cash desk. There is also a risk posed by customers using Money Service Business (MSB) facilities - further details can be found in the section Casinos offering Money Service Businesses (MSBs).
| Vulnerability | Risk | Current likelihood of event occurring | Current impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | High (3) | High (3) | High (9) | No change |
| Operator control | MLRO lacks the independence and resources to uphold their responsibilities | Medium (2) | High (3) | High (6) | No change (new wording) |
| Operator control | Lack of competence of key personnel and licence holders which can potentially be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | High (3) | High (6) | No change |
| Operator control | Lack of adequate and relevant due diligence checks conducted resulting in criminals laundering money | High (3) | High (3) | High (9) | No change |
| Operator control | Inappropriate AML thresholds - including thresholds that are not appropriate for the customer base or are predominantly loss based | High (3) | High (3) | High (9) | New risk |
| Operator control | Lack of appropriate customer monitoring - this includes the risk profiling and ongoing monitoring of customers in a business relationship, as well as the monitoring of customers where CDD has not been completed (for example where customers are allowed entry without formal identification) | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Lack of closed-loop system | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | High (3) | High (6) | New risk |
| Customer | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Customer | Customers who appear on financial sanctions lists laundering funds which are subject to an asset freeze | Low (1) | High (3) | Medium (3) | No change |
| Customer | Foreign politically exposed persons (PEPs) using casinos to launder criminal funds | Medium (2) | High (3) | High (6) | No change |
| Customer | Domestic PEPs using casinos to launder criminal funds | Low (1) | Medium (2) | Low (2) | No change |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds | High (3) | High (3) | High (9) | No change |
| Customer | Domestic PEPs using casinos to clean criminal funds | Low (1) | Medium (2) | Low (2) | No change |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds | High (3) | High (3) | High (9) | Increase in likelihood |
| Customer | Customers breaking up large amounts of cash into small transactions to minimise suspicion and evade customer due diligence (CDD) requirements at the threshold (‘smurfing’) | Medium (2) | High (3) | High (6) | Decrease in likelihood |
| Customer | Use of third parties to obscure the source or ownership of money gambled by customers - this includes agents and money mules | Medium (2) | High (3) | High (6) | No change (new wording) |
| Customer | Customer presents risks relating to their source of income - including access to third party funds or funds originating from a cash intensive business | Medium (2) | Medium (2) | Medium (4) | New risk |
| Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer displays suspicious or unusual wagering patterns – such as minimal play and hedging bets | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer gambles at multiple premises or operators to disguise the source of their funds | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer linked to criminal activity | High (3) | High (3) | High (9) | New risk |
| Geographic | Customers who are a resident of or are linked to high-risk jurisdictions using casino facilities to launder criminal funds | Medium (2) | High (3) | High (9) | No change (new wording) |
| Means of payment | Terminals used to facilitate payments - funds received via this method may not be scrutinised as closely | Medium (2) | Medium (2) | Medium (4) | New risk |
| Means of payment | Cash transactions - this includes the risk of dyed and counterfeit notes | High (3) | High (3) | High (9) | No change (new wording) |
| Means of payment | Casinos acting as money service businesses (MSBs) | High (3) | High (3) | High (9) | No change |
| Means of payment | Cryptoasset transactions | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Scottish banknotes | Low (1) | High (3) | Medium (3) | No change |
| Means of payment | Ticket-in-ticket-out (TITO) enabled machines used to launder criminal funds when used with an automatic ticket redemption (ATR) machine | Medium (2) | Medium (2) | Medium (4) | New risk |
| Product | Electronic roulette used with TITO and ATRs to launder criminal funds | Medium (2) | High (3) | High (6) | No change |
| Product | Gaming machines used to launder criminal funds | Medium (2) | High (3) | High (6) | No change |
| Product | Poker - peer-to-peer gaming presents risks of collusion and the potential transfer of funds between customers | High (3) | High (3) | High (9) | No change (new wording) |
| Licensing and Integrity | Employees colluding with criminals | High (3) | High (3) | High (9) | No change |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations being acquired by organised crime to launder criminal proceeds or the ultimate beneficial ownership is linked to criminal activity | Low (1) | High (3) | Medium (3) | Decrease in likelihood |
Funds originate from a cash-intensive business
A customer was identified as mixing cash they had brought to the premise with sealed packets of cash. The customer declared that their funds were from a cash-intensive business alongside additional employment, but they were not able to provide evidence of the source of funds generated through the cash intensive activity. In addition, further checks identified that the customer was in receipt of Universal Credit and Personal Independence Payments, which raised suspicion that the customer was engaged in tax and benefit fraud.
Scrutiny of source of funds
A customer provided source of funds evidence that raised suspicion as it appeared similar to a bank statement already held on file. Further scrutiny identified that the statement had been edited to falsely represent transactions and the total account balance.
1 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics.
2 Home Office and HM Treasury National Risk Assessment of Money Laundering and Terrorist Financing (opens in new tab) (PDF), July 2025.
Casinos offering services to customers including acting as a cheque casher or currency exchange, accepting winners’ cheques and foreign currency, or transmitting money are considered to be providing Money Service Business (MSB) services under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations)(opens in a new tab). Under the Regulations, the Gambling Commission is the supervisory authority for casinos in the UK and HM Revenue and Customs (HMRC) is the supervisory authority for MSBs. The Commission and HMRC have agreed, under Regulation 7(2) of the Regulations, that the Commission will act as the supervisory authority for MSB activities conducted in casinos.
All types of MSB activity carry money laundering and terrorist financing (ML/TF) risk as they could be used by criminals to break their funds up and conceal its source or destination, which makes it harder for the flow of funds to be tracked and disrupted. Foreign currency exchange activity may result in funds derived from crime in foreign countries infiltrating the UK’s financial system. MSB transactions may be one-off in nature and funds can be transferred globally.
It is noted in the National Risk Assessment of Money Laundering and Terrorist Financing (opens in new tab) (PDF) that money laundering risks associated with MSBs has not changed since the 2020 publication and remains high overall. In addition, the terrorist financing risks associated with MSBs remains high. We note that MSBs in casinos operate in different circumstances to retail MSBs, however we consider that the activity remains high risk.
In 2024, the Commission found that approximately 3 percent of remote casino licensees offered some form of MSB activity1. In the same period, approximately 56 percent of non-remote casino licensees also offered some form of MSB activity2. It must be noted that a licensee can operate multiple premises and not all those premises will offer MSB activity.
Commission research found that:
MSB activity decreased significantly during 2022, and has remained stable at a lower level since then. The estimated value of MSB activity in casinos in 2024 was £70 million. The transactions conducted remain high value and can involve multiple currencies.
Customer ‘red flag’ indicators include:
Operator vulnerabilities in relation to MSB activity are:
MSBs should be viewed in the context of a wide range of money laundering typologies and a constantly evolving threat picture.
HMRC provide guidance on meeting the requirements for offering MSB activity - for further information see Money laundering: understanding risks and taking action for money service businesses (opens in new tab) and Money service business guidance for money laundering supervision (opens in new tab).
1 This figure relates to casino licenses offering business to customer activity and does not include casino host licences.
2 In the period 1 January 2024 to 31 December 2024.
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Betting (remote) | High | High |
The remote betting sector continues to be rated high risk for money laundering.
The sector has the potential to be exploited through customers structuring bets to minimise risk, peer-to-peer activity and customers colluding to bet on events that have been fixed by participants.
Remote betting has a high level of transactions with the gross gambling yield (GGY) for the sector in the period April 2024 to March 2025 totalling £2.6 billion1.
The remote sector faces challenges as a result of customers not being present for verification purposes. This includes the use of fraudulent documentation to bypass know your customer (KYC) controls, as well as the risk of mule accounts being created. Developments in artificial intelligence (AI) tools create further difficulties. The Commission is aware of an increase in the scale and sophistication of attempts to bypass KYC checks using false documentation, deepfake videos and face swaps generated by artificial intelligence.
The remote sector is also exposed to financial flows from higher risk payment methods, including e-wallets, pre-paid methods and the presence of funds linked to cryptoassets. Further risks can be present when customers use multiple methods of payment, or an open-loop system is in operation.
| Vulnerability | Risk | Current likelihood of event occurring | Current impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | High (3) | High (3) | High (9) | No change |
| Operator control | Lack of competency of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | High (3) | High (6) | No change |
| Operator control | Inadequate ‘know your customer’ (KYC) measures on customers who are not physically present for verification - this includes the failure to obtain additional information following a risk based approach | High (3) | High (3) | High (9) | No change (new wording) |
| Operator control | Lack of appropriate customer and transaction monitoring | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Inappropriate AML thresholds - including thresholds that are not appropriate for the customer base or are predominantly loss based | High (3) | High (3) | High (9) | No change (new wording) |
| Operator control | Pool betting operators staking and winning directly and indirectly on their own products | Low (1) | Medium (2) | Low (2) | No change (new wording) |
| Operator control | Inadequate due diligence on white-label partnerships | High (3) | High (3) | High (9) | No change (new wording) |
| Operator control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) | New risk |
| Operator control | Inappropriate controls relating to linked or duplicate accounts - this includes identifying linked accounts and, where multiple accounts are permitted, applying controls across accounts | High (3) | High (3) | High (9) | New risk |
| Operator control | Lack of closed-loop system | Medium (2) | High (3) | High (6) | No change |
| Operator control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds - this includes the use of AI tools to generate documents or videos | High (3) | High (3) | High (9) | No change (new wording) |
| Customer | Customer gambles with multiple remote operators to disguise the source of their funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Customer | Customers who appear on financial sanctions lists laundering funds which are subject to an asset freeze | Low (1) | High (3) | Medium (3) | No change |
| Customer | Third party use of customer accounts to obscure the source of funds and identity of the user - this includes the creation of mule accounts and the use of agents | High (3) | High (3) | High (9) | No change (new wording) |
| Customer | Customers making numerous low-level transactions to minimise suspicion and evade thresholds (smurfing) | Medium (2) | High (3) | High (6) | Decrease in likelihood (new wording) |
| Customer | Politically exposed persons (PEPs) | Medium (2) | High (3) | High (6) | No change | Customer | Customer presents risks relating to their source of income - including access to third party funds or funds originating from a cash-intensive business | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) | New risk | Customer | Customer uses a third-party payment method that is not in their name | Medium (2) | High (3) | High (6) | New risk | Customer | Customer displays suspicious or unusual wagering patterns - including placing large bets on 'safe' odds, betting on obscure markets or on events where the integrity has been called into question, as well as use of early 'cash out' features | Medium (2) | High (3) | High (6) | New risk | Customer | Customer linked to criminal activity | High (3) | High (3) | High (9) | New risk | Geographic | Customers who are a resident of or are linked to a high-risk jurisdiction using gambling facilities to launder criminal funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Means of payment | E-wallets | Medium (2) | Medium (2) | Medium (4) | No change |
| Means of payment | Cryptoasset transactions | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Pre-paid methods including vouchers and cards - this payment method can make it difficult to identify the source of funds | Medium (2) | High (3) | High (6) | Decrease in likelihood (new wording) |
| Means of payment | Multiple methods of payment | Medium (2) | High (3) | High (6) | No change |
| Product | Peer-to-peer betting - there is a risk of the transfer of funds through betting exchange and small pool groups | High (3) | High (3) | High (9) | No change (new wording) |
| Product | Unregulated betting events | Medium (2) | High (3) | High (6) | No change | Product | High-profile events - where there is a significant increase in betting activity there are increased transactions to monitor and previously unknown customers may place large bets | Medium (2) | High (3) | High (6) | New risk |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Betting operations being acquired or run by organised criminals to launder funds | Low (1) | High (3) | Medium (3) | No change |
Suspicious wagering
A customer displayed suspicious betting patterns, placing high stakes bets with low odds and cashing out bets early. The betting activity was a change from the normal activity on the account and the customer refused to cooperate with requests for documents.
Mule accounts
A customer who previously had minimal activity on their account made a £10,000 deposit in the early hours of the morning. The customer then requested to withdraw the funds without wagering them. Source of funds enquiries revealed that the customer was a student who was not in receipt of a regular income. The customer had also received multiple transfers from third parties and was suspected of money mule activity.
Scrutiny of source of funds
A student with no formal employment was asked for source of funds information by an operator as part of know your customer (KYC) checks. The student provided a bank statement which showed them making large cash deposits into their bank account, which was followed by smaller transfers to other individuals with the payment references naming other gambling operators.
Multiple accounts and false or stolen identity documents
A customer deposited approximately £40,000 over the course of 6 months, creating accounts using the details of 5 different individuals.
Circumvention of identity verification controls
A customer, whose account had previously been blocked due to suspicion of money laundering, was able to circumvent identity verification checks at sign-up and create a new account. Operator controls were insufficient to identify small discrepancies within customer sign-up data fields.
Inadequate due diligence on white-label partnerships
A Commission investigation found that a licensed operator with white-label partnerships had failed to carry out effective due diligence on the ownership of the third party, as well as the source of funds for the business relationship. The operator had also not sufficiently considered whether any activity by the white-label partner was illegal, either in Britain or the territory in which it was conducted.
1 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics.
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Betting (non-remote) | High | High |
| Off-course | High | High |
| On-course | Medium | Medium |
The non-remote betting sector continues to be rated as high risk for money laundering.
The sector has the potential to be exploited through anonymous customers structuring bets to minimise risk, colluding to bet on fixed events and laundering funds through gaming machines.
Non-remote betting has a high level of transactions. The gross gambling yield (GGY) for the sector in the period April 2024 to March 2025 was £2.5 billion, of which approximately £28 million was in respect of on-course betting1.
Cash is a risk for both on-course and off-course betting, especially when large bets are placed by anonymous customers. In the off-course sector there is potential for open-loop systems to exist where customer activity can take place across different channels (online and in premises) and across premises.
There can be challenges to monitoring customers in the live premises environment across different products, including activity on self-service betting terminals and gaming machines. High-profile events, such as Cheltenham Festival and Royal Ascot, can also present challenges for customer monitoring due to high levels of customer activity and bets being placed by new and unfamiliar customers.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance (off-course only) | High (3) | High (3) | High (9) | No change | Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance (on-course only) | Medium (2) | Medium (2) | Medium (4) | No change | Operator control | Lack of competence of key personnel and licence holders, which can be exploited by criminals seeking to launder the proceeds of crime (off-course) | Medium (2) | High (3) | High (6) | New risk | Customer | Lack of competence of key personnel and licence holders, which can be exploited by criminals seeking to launder the proceeds of crime (on-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Operator control | Inadequate know your customer (KYC) measures - including failure to obtain additional information following a risk-based approach (off-course) | Medium (2) | High (3) | High (6) | Decrease in likelihood (new wording) | Operator control | Inadequate know your customer (KYC) measures - including failure to obtain additional information following a risk-based approach (on-course) | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Operator control | Lack of appropriate customer activity and transaction monitoring - this includes interactions with customers and monitoring play across different products (off-course) | Medium (2) | High (3) | High (6) | New risk | Operator control | Lack of appropriate customer activity and transaction monitoring (on-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Operator control | Lack of closed-loop system - where appropriate this includes consideration of transactions across channels and premises (off-course and on-course) | Medium (2) | High (3) | High (6) | No change (new wording) | Operator control | Accepting remote bets without the appropriate licence (on-course) | Low (1) | Medium (2) | Low(2) | No change | Operator control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) | No change | Operator control | Inappropriate AML thresholds - including thresholds that are not appropriate for the customer base or are predominantly loss based (off-course and on-course) | Medium (2) | High (3) | High (6) | New risk | Operator control | Failure to appropriately scrutinise source of funds documents (off-course only) | Medium (2) | High (3) | High (6) | New risk | Operator control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | High (3) | High (6) | New risk | Customer | Customer gambles at multiple premises or operators to disguise the source of their funds (off-course and on-course) | Medium (2) | High (3) | High (6) | Reduced likelihood (new wording) | Customer | False or stolen identification documentation used to bypass controls to launder criminal funds (off-course and on-course) | Medium (2) | High (3) | High (6) | No change | Customer | Customer linked to criminal activity (off-course and-on course) | High (3) | High (3) | High (9) | New risk | Customer | Customer presents risks relating to their source of income - including access to third party funds or funds originating from a cash-intensive business (off-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer appears to be a disproportionate spender (off-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer gambles with stolen or fraudulent card (off-course and on-course) | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer displays suspicious or unusual wagering patterns - including placing large bets on 'safe' odds, betting on obscure markets or on events where the integrity has been called into question, as well as use of early 'cash out' features on self-service betting terminals (SSBTs) (off-course and on-course) | Medium (2) | High (3) | High (6) | No change | Means of payment | Cash transactions - this includes the risk of dyed and counterfeit notes (off-course and on-course) | High (3) | High (3) | High (9) | No change (new wording) | Means of payment | Scottish banknotes (off-course and on-course) | Low (1) | High (3) | Medium (1) | No change | Product | Gaming machines used to launder criminal funds (off-course only) | Medium (2) | High (3) | High (6) | No change | Product | Self Service Betting Terminals and Ticket-in-Ticket-Out Machines used to launder criminal funds (off-course only) | Medium (2) | High (3) | High (6) | No change | Product | High-profile events - where there is a significant increase in betting activity there are increased transactions to monitor and previously unknown customers may place large bets | Medium (2) | High (3) | High (6) | New risk | Licensing and integrity | Betting employees acting in collusion with organised criminals to launder criminal funds (off-course only) | Medium (2) | High (3) | High (6) | No change |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Betting operations being acquired or run by organised criminals to launder funds (on-course only) | Low (1) | High (3) | Medium (3) | No change | Licensing and integrity | Betting operations being acquired or run by organised criminals to launder funds (off-course only) | Low (1) | High (3) | Medium (3) | No change |
Scottish banknotes
Scottish banknotes have been placed in machines with the potential aim of being paid out in English notes or by debit card, examples include:
Lack of 'closed loop' system
A customer loaded £4,000 cash into a self-service betting terminal and requested that the funds be debited to their card.
Employees colluding with customers
A customer who had been suspended due to not providing requested documentation was able to place bets by transferring money to staff members bank accounts who then proceeded to place cash bets on the customer’s behalf.
Gaming machines
A Commission investigation found that a licensed operator did not have appropriate systems in place to monitor customer activity on B3 gaming machines, as the monitoring reports did not allow the operator to assess customers’ overall spend.
A customer employed by a cash-intensive business used cash to load a gaming machine but, after minimal play, requested funds be paid back to their debit card.
1Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics.
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Bingo (remote) | High | High |
Remote bingo as a sector continues to be rated as high risk for money laundering.
Bingo as a product presents limited risk for money laundering exploitation, however the sector is exposed to the risks present across the remote sector, in particular because the majority of remote bingo licences are held alongside remote casino licences.
In comparison to other remote sectors, remote bingo has a lower level of transactions. The gross gambling yield (GGY) for the sector for the period April 2024 to March 2025 was £166 million1.
The remote sector faces challenges as a result of customers not being present for verification purposes. This includes the use of fraudulent documentation to bypass know your customer (KYC) controls and the risk of mule accounts being created. Developments in artificial intelligence (AI) tools create further difficulties. The Commission is aware of an increase in the scale and sophistication of attempts to bypass KYC checks using false documentation, deepfake videos and face swaps generated by AI.
The remote sector is also exposed to financial flows from higher risk payment methods, including e-wallets, pre-paid methods and the presence of funds linked to cryptoassets. Further risks can be present when customers use multiple methods of payment, or an open-loop system is in operation.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator Control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | High (3) | High (3) | High (9) | No change |
| Operator control | Lack of competence of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Inadequate ‘know your customer’ (KYC) measures on customers who are not physically present for verification - this includes the failure to obtain additional information following a risk-based approach | High (3) | High (3) | High (9) | No change |
| Operator control | Lack of appropriate customer and transaction monitoring | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Inappropriate AML thresholds - including thresholds that are not appropriate for the customer base or are predominantly loss based | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) | New risk |
| Operator control | Lack of closed loop system | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Inappropriate controls relating to linked or duplicate accounts - this includes identifying linked accounts and, where multiple accounts are permitted, applying controls across accounts | Medium (2) | High (3) | High (6) | New risk |
| Operator control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds - this includes the use of AI tools to generate documents or videos | High (3) | High (3) | High (9) | Increase in likelihood (new wording) |
| Customer | Customer gambles with multiple remote operators to disguise the source of their funds | Low (1) | Medium (2) | Low (2) | Decreased in likelihood and impact |
| Customer | Customers making numerous low-level transactions to minimise suspicion and evade thresholds (smurfing) | Medium (2) | High (3) | High (6) | No change |
| Customer | Customers who appear on financial sanctions lists laundering funds which are subject to an asset freeze | Low (1) | High (3) | Medium (3) | No change |
| Customer | Third party use of customer accounts to obscure the source of funds and identity of the user - this includes the creation of mule accounts and the use of agents | Medium (2) | High (3) | High (6) | No change |
| Customer | Customer presents risks relating to their source of income - including access to third party funds or funds originating from a cash intensive business | Medium (2) | Medium (2) | Medium (4) | New risk |
| Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer uses a third-party payment method that is not in their name | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer displays suspicious or unusual wagering patterns - such as withdrawal after minimal play | Medium (2) | High (3) | High (6) | New risk |
| Customer | Customer linked to criminal activity | Medium (2) | High (3) | High (6) | New risk |
| Geographic | Customers who are a resident of or are linked to a high-risk jurisdiction using gambling facilities to launder criminal funds | Low (1) | High (3) | Medium (3) | New risk |
| Means of payment | Multiple methods of payment | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Cryptoasset transactions | Medium (2) | High (3) | High (6) | No change |
| Means of payment | Pre-paid methods including vouchers and cards - this payment method can make it difficult to identify the source of funds | Medium (2) | High (3) | High (6) | No change (new wording) |
| Means of payment | E-wallets | Medium (2) | Medium (2) | Medium (4) | No change |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations run by organised criminals to launder criminally derived funds | Low (1) | High (3) | Medium (3) | No change |
Scrutiny of source of funds
A customer’s bank statement showed unusual transactions, with the customer regularly receiving small amounts from third parties. Open-source checks identified that the customer was running illegal lotteries through social media.
After a customer’s deposits increased significantly, source of funds checks were conducted and revealed large third-party transfers from a relative. On further enquiry, the customer stated that the funds were received through a power of attorney arrangement which could not be evidenced, raising concerns about the misuse of a vulnerable third party’s funds. The customer’s bank statement showed that funds received from the relative had been used across multiple gambling operators.
Multiple accounts and false or stolen identity documents
A customer deposited approximately £40,000 over the course of 6 months, creating accounts using the details of 5 different individuals.
Circumvention of identity verification controls
A customer, whose account had previously been blocked due to suspicion of money laundering, was able to circumvent identity verification checks at sign-up and create a new account. Operator controls were insufficient to identify small discrepancies within customer sign-up data fields.
1 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Bingo (non-remote) | Medium | Medium |
Non-remote bingo as a sector continues to be rated as medium risk for money laundering.
Bingo as a product presents limited risk for money laundering exploitation, however risks associated with monitoring customers in a live premises environment remain in the sector, including the monitoring of gaming machine activity.
The gross gambling yield (GGY) for the non-remote bingo sector for the period April 2024 to March 2025 was £650.4 million. Of this, £424 million was generated through gaming machine activity1.
When gaming machines are used in conjunction with ticket-in-ticket-out machines and automatic ticket redemption machines, there is a risk that staff have less oversight of the transactions.
Many bingo premises operate a membership system. This control can aid in verifying the identity of customers and tracking their activity. In premises where a membership system is not operated, the potential risk posed by anonymous customers is heightened. Bingo licensees who operate AGC-style premises should consider all relevant money laundering and terrorist financing risks to the premises, including those noted in the bingo and arcade sections of this risk assessment.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator Control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Medium (2) | Medium (2) | Medium (4) | No change | Operator Control | Lack of competence of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Inadequate know your customer (KYC) checks conducted resulting in criminals laundering criminal proceeds - including failure to obtain additional information following a risk-based approach | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Operator Control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Operator Control | Lack of appropriate customer and transaction monitoring. This includes monitoring play on gaming machines, and across different products | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Lack of closed-loop system | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Premises converted from adult gaming centres (AGC) - these premises may have anonymous customers | Medium (2) | Medium (2) | Medium (4) | New risk | Customer | Customer gambles at multiple premises or operators to disguise the source of their funds | Medium (2) | Medium (2) | Medium (4) | New risk | Means of Payment | Ticket-in-ticket-out (TITO) facilities used to launder funds when used in conjunction with Automatic Ticket Redemptions machines (ATR) | Medium (2) | Medium (2) | Medium (4) | No change | Means of Payment | Cash transactions - this includes the risk of dyed and counterfeit notes | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Means of Payment | Scottish banknotes | Low (1) | Medium (2) | Low (2) | No change | Product | Electronic Bingo Terminals (EBTs) including table-top gaming (either traditionally or via EBT content) | Low (1) | Medium (2) | Low (2) | No change | Product | Gaming machines used to launder criminal funds | Medium (2) | Medium (2) | Medium (4) | Increase in likelihood |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations being acquired by organised crime to launder criminal proceeds | Low (1) | Medium (2) | Medium (3) | No change |
Scottish banknotes
Scottish banknotes were placed in machines with the potential aim of being paid out in English notes or by using a debit card. In one case, customers placed approximately £6,000 in Scottish notes into gaming machines in a premise.
Gaming machines
A Commission investigation found that a licensed operator did not have appropriate systems in place to monitor customer activity on B3 gaming machines, as the monitoring reports did not allow the operator to assess customers’ overall spend.
A customer employed by a cash-intensive business used cash to load a gaming machine, but after minimal play requested funds be paid back to their debit card.
1Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Gambling software (remote and non-remote) | Low | Medium |
The gambling software sector has increased from low to medium risk for money laundering.
This is due to the risk posed by business-to-business relationships and the risk of licensed operators supplying software to illegal website operators. For further information on this risk, refer to the section on illegal markets.
The sale of software to illegal website operators may not be by a licensed operator directly but may result from insufficient monitoring of third-party contracts and activity. As software supply can involve cross-border arrangements with multiple parties, there is a greater potential for money laundering exploitation.
Gambling software businesses may also receive funds in the form of cryptoassets or from businesses offering cryptoasset activity. This has been noted as occurring through business relationships and investments.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Low (1) | Medium (2) | Low (2) | Increase in impact | Operator control | Inadequate due diligence checks on third party business relationships - including business-to-business customers and test houses. | Medium (2) | High (3) | High (6) | Increase in impact and likelihood (new wording) | Operator control | Inadequate due diligence checks on business investors | Medium (2) | Medium (2) | Medium (4) | Increase in likelihood (new wording) | Operator control | Insufficient monitoring of third-party contracts to identify the resale of software to unlicensed sites | Medium (2) | Medium (2) | Medium (4) | New risk | Means of payment | Cryptoasset transactions | Medium (2) | High (3) | High (6) | New risk | Geographic | B2B partner is based in or linked to a high-risk jurisdiction | Medium (2) | Medium (2) | Medium (4) | New risk |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations run or acquired by organised criminals to launder criminally-derived funds | Low (1) | Medium (2) | Low (2) | New risk |
Business investors
A gambling software company received a loan where the ultimate source of funds was revenue from a remote casino offering cryptoasset facilities. The Commission identified that the due diligence checks conducted on the remote casino were insufficient. Further investigation showed that the casino was encouraging circumvention of geo-blocking controls by customers by describing how this can be achieved.
A business applying for a licence had obtained funding through an Initial Coin Offering (ICO), which is a fundraising method where a project sells cryptoasset tokens to investors. The majority of the funds used to buy the tokens were from cryptoassets, such as Bitcoin, Ethereum and Tether. The business’ due diligence checks on the ICO investors were insufficient as source of funds checks had not been completed and, in some cases, the identity documents collected could not be linked to the list of ICO investors. Additionally, the due diligence checks completed on other business investors were insufficient. The Commission identified that one investor had been convicted for a money laundering offence.
Software supply to illegal sites
The games used by a licensed operator appeared on an unlicensed gambling website as a result of the software reseller entering into an agreement with the operator of the unlicensed gambling website. Software businesses may be at risk of accepting proceeds of crime generated by illegal gambling activity through third party arrangements.
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Adult Gaming Centres (AGCs) | Medium | Medium | Family Entertainment Centres (FECs) | Low | Low |
The Adult Gaming Centre (AGC) sector continues to be rated as medium risk for money laundering.
The sector faces risks associated with the monitoring of gaming machine activity in a live premises environment. When gaming machines are used in conjunction with ticket-in-ticket-out machines and automatic ticket redemption machines, there is a risk that staff have less oversight of the transactions.
The level of activity in AGCs has increased since the previous risk assessment. For the period April 2022 to March 2023, gross gambling yield (GGY) in the sector was £561 million and, for the period April 2024 to March 2025, it rose to £683 million1.
It has been identified in casework that some AGCs operate staff bonus schemes. There is the potential for staff to be incentivised to overlook money laundering risks presented by customers under such schemes, if appropriate safeguards are not in place.
Family Entertainment Centres remain low risk. The low-level nature of transactions in the sector means that there is limited potential for the sector to be exploited for money laundering. For the period April 2022 to March 2023, gross gambling yield (GGY) in the sector was £40 million2.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator Control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Medium (2) | Medium (2) | Medium (4) | Increase in likelihood | Operator Control | Lack of competence of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime (AGCs only) | Medium (2) | Medium (2) | Medium (4) | Increase in likelihood | Operator Control | Lack of competence of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime (FECs only) | Low (1) | Low (1) | Low (1) | Decrease in likelihood | Operator Control | Inadequate ‘know your customer’ (KYC) measures - including failure to obtain additional information following a risk-based approach (AGC only) | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Lack of appropriate customer activity and transaction monitoring (AGC only) | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Lack of closed-loop system | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) | New risk | Operator Control | Staff bonus schemes creating an incentive to overlook money laundering risks | Low (1) | Medium (2) | Low (2) | New risk | Operator Control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Low (1) | Medium (2) | Low (2) | No change (new wording) | Customer | Customer gambles at multiple premises or operators to disguise the source of their funds | Medium (2) | Medium (2) | Medium (4) | New risk | Means of Payment | Cash transactions - this includes the risk of dyed and counterfeit notes | Medium (2) | Medium (2) | Medium (4) | No change (new wording) | Means of Payment | Ticket-in-ticket-out (TITO) facilities used to launder funds when used in conjunction with ATR machines (AGCs only) | Medium (2) | Medium (2) | Medium (4) | Increase in likelihood | Means of Payment | Scottish banknotes | Low (1) | Medium (2) | Low (2) | No change | Product | Gaming machines being used to launder criminally derived funds (AGCs only) | Medium (2) | Medium (2) | Medium (4) | No change |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Arcade businesses being acquired by organised crime to launder criminal proceeds (AGCs only) | Low (1) | Medium (2) | Low (2) | No change | Licensing and integrity | Arcade businesses being acquired by organised crime to launder criminal proceeds (FECs only) | Low (1) | Low (1) | Low (1) | No change |
Scottish banknotes
Scottish banknotes have been placed in machines with the potential aim of being paid out in English notes or by debit card. In one case, customers placed approximately £6,000 in Scottish notes into gaming machines in a premise.
Dyed notes
Several hundred pounds of stained notes were found in gaming machines located in an AGC.
Gaming machines
A Commission investigation found that a licensed operator did not have appropriate systems in place to monitor customer activity on B3 gaming machines, as the monitoring reports did not allow the operator to assess customers’ overall spend.
A customer employed by a cash-intensive business used cash to load a gaming machine, but after minimal play requested funds be paid back using their debit card.
1Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics
2 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Society lotteries (remote and non-remote) | Low | Low | External Lottery managers (remote and non-remote) | Low | Low |
Society lotteries and external lottery managers (ELMs) remain low risk for money laundering. As a product, lotteries pose limited potential for money laundering exploitation, although there is the potential for the integrity of operations to be undermined or for lottery proceeds to be misused.
Large society lotteries licensed by the Commission are a sector of significant size. In the period April 2024 to March 2025, large society lotteries ticket sales totalled £1.1 billion1.
New offerings in the lottery sector, such as the use of pre-paid gift cards as a payment method, present potential risks if appropriate know-your-customer measures are not implemented.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator Control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Low (1) | Medium (2) | Low (2) | Increase in impact | Operator Control | Lack of competence of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime | Low (1) | Medium (2) | Low (2) | New risk | Operator Control | Inadequate know your customer (KYC) measures - including for customers who are not physically present | Low (1) | Low (1) | Low (1) | New wording | Operator Control | Training for staff is insufficient and is not appropriately tailored | Low (1) | Low (1) | Low (1) | New risk | Operator Control | Licensees failing to transfer lottery proceeds to charities | Low (1) | Medium (2) | Low (2) | No change | Operator Control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Low (1) | Medium (2) | Low (2) | Increase in impact (new wording) | Operator Control | Lack of closed-loop system | Low (1) | Medium (2) | Low (2) | New risk | Customer | False and stolen identity documentation | Low (1) | Low (1) | Low (1) | No change | Means of Payment | Cash transactions - this includes the risk of dyed and counterfeit notes (non-remote only) | Low (1) | Medium (2) | Low (2) | Increase in impact (new wording) | Means of Payment | Pre-paid entry, including gift cards, for example lottery subscription gift cards | Low (1) | Medium (2) | Low (2) | New risk | Product | Scratch cards or interactive instant win games | Low (1) | Low (1) | Low (1) | No change | Licensing and integrity | Scratch cards or interactive instant win games | Low (1) | Low (1) | Low (1) | No change (new wording) |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Operator links to organised crime result in laundering of criminal funds | Low (1) | Low (1) | Low (1) | No change (new wording) |
Licensee failing to transfer lottery proceeds to charities
An external lottery manager (ELM) was convicted of misusing lottery proceeds. The Chief Executive Officer of the ELM used lottery proceeds to cover the costs of running the business and failed to pass on the proceeds to charities.
1 Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| National Lottery | Low | Low |
The National Lottery remains low risk for money laundering.
As a product, lotteries pose limited potential for money laundering exploitation. In addition, the Gambling Commission has a legal responsibility to ensure that the National Lottery is run with all due propriety.
The National Lottery represents a significantly sized portion of gambling activity in the UK. In the period April 2024 to March 2025, National Lottery ticket sales totalled £7.9 billion1.
The impact scores assigned to risks, including regulatory compliance and acquisition by organised crime, have increased since 2023. This reflects further consideration of the scale of gambling activity in the sector, rather than new evidence.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator control | National Lottery operator failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Low (1) | Medium (2) | Low (2) | Increase in impact | Operator control | Lack of competence of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime | Low (1) | Medium (2) | Low (2) | New risk | Operator control | Inadequate know your customer (KYC) measures - including for customers who are not physically present | Low (1) | Low (1) | Low (1) | No change |
| Operator control | Training for staff is insufficient and is not appropriately tailored | Low (1) | Low (1) | Low (1) | New risk | Operator control | Lack of closed-loop system | Low (1) | Medium (2) | Low (2) | New risk | Customer | False and stolen identity documentation | Low (1) | Low (1) | Low (1) | No change | Means of payment | Cash transactions | Low (1) | Low (1) | Low (1) | No change | Product | Scratch cards and/or interactive instant win games | Low (1) | Low (1) | Low (1) | No change |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | National Lottery acquired by organised crime to launder criminal funds | Low (1) | High (3) | Medium (3) | Increase in impact |
1Industry Statistics - Annual report - Financial year April 2024 to March 2025 - Official statistics
| Sector | Previous overall risk rating | Current overall risk rating |
|---|---|---|
| Gaming machine technical (remote and non-remote) | Low | Low |
The gaming machine technical sector continues to be low risk for money laundering.
There is little potential for money laundering exploitation of the sector. However, there is the risk of licensed operators supplying machines to premises without appropriate licensces and facilitating illegal gambling. This risk can be mitigated by licensed operators conducting appropriate due diligence checks on third-party suppliers.
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Operator control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Low (1) | Low (1) | Low (1) | No change | Operator control | Inadequate due diligence checks on third parties, including customers and suppliers - this includes ensuring machines are only supplied to licensed premises | Medium (2) | Medium (2) | Medium (4) | Increase in impact | Operator Control | Lack of adherence with the Technical Standards, including requirements for machine credit and payment, and machine identification | Low (1) | Low (1) | Low (1) | No change | Operator control | Inadequate due diligence checks on business investors. | Low (1) | Medium (2) | Low (2) | No change |
| Vulnerability | Risk | Likelihood of event occurring | Impact of event occurring | Overall risk | Change in risk |
|---|---|---|---|---|---|
| Licensing and integrity | Gambling operations run by organised criminals to launder funds | Low (1) | Medium (2) | Low (2) | New risk |
Illegal siting of gaming machines
Gaming machines have been found in premises offering illegal gambling and in venues which are not licensed to offer gaming machines, such as takeaway venues and cafés.
| 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).
| 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) |
Some potential ‘red flag’ indicators that operators should be aware of are:
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.
1The Home Office publishes the list of proscribed organisations (opens in new tab) .
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:
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.
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.
This risk assessment is focused on the risks present in the licensed gambling industry, however the National Risk Assessment of Money Laundering and Terrorist Financing (opens in new tab) (PDF) (the NRA) identified the money laundering (ML) and terrorist financing (TF) risks posed by illegal gambling. The NRA noted that there has been an increase in illegal casinos targeting the UK. Illegal gambling can both generate proceeds of crime and be used to launder the proceeds of crime.
Illegal gambling sites are not supervised by the Gambling Commission, nor do they comply with the regulatory framework in place, which includes the Licence Conditions and Codes of Practice (LCCP) and the Money Laundering and Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (opens in new tab). The lack of regulation allows high-value activity to be conducted without the necessary oversight and reporting procedures. Illegal gambling sites are vulnerable to exploitation for ML and TF purposes, and they undermine the integrity of the gambling industry.
Gambling sites can also be established and operated by organised crime groups using their proceeds of crime, as has been identified in Southeast Asia where illegal online gambling platforms have been used by transnational organised crime groups to disguise illicit financial flows1.
Payment service providers act to facilitate the transfer of funds from British consumers to illegal sites. The payment processors are the first regulated financial link through which funds from illegal gambling are filtered into the legitimate financial system.
Illegal gambling sites also increasingly allow the use of cryptoassets as a means of payment. Cryptoassets carry heightened ML and TF risks due to the potential exposure to high-risk jurisdictions, including sanctioned entities; their ability to move high volumes at speed; regulatory gaps that make it possible for users to remain anonymous, as well as anonymity enhancing services; and their association with criminal activity.
To tackle this threat, HM Government has allocated £26 million over 3 years to the Gambling Commission to intensify its focus on disrupting the illegal gambling markets, utilising new powers and working in close collaboration with partner agencies to attack illegal activity across the supply chain. While this enhanced enforcement targets unlicensed operations, a compliant, mature and resilient regulated industry serves as a critical baseline defence. By strictly adhering to statutory safeguards and reporting concerns, and maintaining rigorous transaction oversight, the regulated sector minimises exposure to ML and TF, effectively mitigating risk displacement and safeguarding the broader economy against vulnerabilities identified by the Financial Action Task Force (FATF).
Further information can be found in the Commission’s publications on tackling illegal gambling.
1United Nations Office of Drugs and Crime ‘Transnational Organized Crime and the Convergence of Cyber-Enabled Fraud, Underground Banking and Technological Innovation in Southeast Asia: A Shifting Threat Landscape’ (opens in new tab)(PDF), October 2024.