The Gambling Commission has released its anticipated risk assessment for 2026, examining money laundering (ML) and terrorist financing (TF) vulnerabilities within the licensed gambling industry in Great Britain.
Covering data spanning from April 1, 2023, to October 31, 2025, the report identifies remote and non-remote casinos, along with betting activities, as the subsectors facing the highest risk. In contrast, sectors like the National Lottery and society lotteries are viewed as low-risk environments.
Commission data indicates that from April 2024 to March 2025, remote casino gross gambling yield (GGY) reached £5 billion, with slot games generating £4.2 billion. Remote betting contributions amounted to £2.6 billion, while non-remote betting brought in £2.5 billion, with merely £28 million attributed to on-course betting.
To assess risk, the Commission applied a formula to measure the potential exploitation for money laundering across different sectors. Although the National Risk Assessment categorized casino TF risk as low, the Commission rated it as medium overall, considering the severe repercussions that incidents of terrorist financing could carry.
Peer-to-peer gambling products, such as poker and betting exchanges, have been recognized as particularly vulnerable to money laundering risks. Poker received a “high” ML risk rating in both remote and non-remote casino settings, while peer-to-peer betting, especially in remote scenarios, was similarly classified. Additionally, the gambling software sector's risk status has been reassessed from low to medium, highlighting the cross-border risks associated with software supply, including potential distribution to unlicensed operators.
Identified technical vulnerabilities included issues with automatic ticket redemption systems in gaming machines and self-service betting terminals, which the report flag as contributors to risk.
The risk factors associated with payment methods were also underscored. The growing use of e-wallets, pre-paid cards, and cryptocurrencies particularly in remote sectors increases opportunities for criminal activities. Complex payment systems utilizing multiple methods further create concealment advantages for illicit actors.
Earlier this year, the Commission initiated a taskforce aimed at investigating illegal gambling prevalence. This group will specifically examine online operators’ payments and will convene biannually as part of a year-long commitment to address these issues.
A significant point made in the report was the increasing sophistication in criminal techniques designed to evade customer due diligence, including the use of sophisticated false documents such as deepfakes and AI-generated fraudulent identities.
Failures on the operator's part significantly contribute to ML and TF risk. The Commission observed inadequate anti-money laundering (AML) and counter-terrorist financing (CTF) policies and controls in various subsectors, alongside poorly trained personnel. It also noted the inappropriate establishment of AML thresholds and weak monitoring of linked or duplicate accounts.
Particularly troubling was the Commission’s finding of insufficient oversight of white-label partnerships and business-to-business relationships, indicating these areas pose notable risks.
Interestingly, white-label partnerships just recently evaded scrutiny in the Department for Culture, Media and Sport (DCMS)’s consultation regarding a ban on unlicensed gambling sponsorships across the industry. This consultation proposed criminalizing promotions for unlicensed operators using secondary legislation under the Gambling Act 2005.
Furthermore, the report highlighted risks associated with casinos engaging in Money Service Business (MSB) functions like foreign currency exchange and cheque cashing. It revealed that in 2024, about 3% of remote casino license holders and 56% of their non-remote counterparts offered MSB services, with an estimated transaction volume of £70 million linked to MSB activities.
Common indicators of MSB-related money laundering include multiple small foreign-exchange transactions, activities involving high-risk jurisdictions, and discrepancies between deposited and withdrawn currencies.
The report signaled a notable uptick in illegal gambling activity, particularly within unregulated casinos that often accept cryptocurrencies and operate without oversight. Such illegal operations are frequently linked to organized crime, aiding in both revenue generation and laundering efforts.
In response to the increasing threats posed by illegal gambling, the UK government has dedicated £26 million over three years to enhance the Gambling Commission's capability to tackle illegal markets and their associated vulnerabilities in payment chains. Just earlier this week, authorities arrested two individuals during a coordinated operation targeting an alleged illegal casino located in Bristol.
