On Thursday, the Gambling Commission released its much-anticipated risk assessment report for 2026, addressing vulnerabilities related to money laundering (ML) and terrorist financing (TF) within Britain’s licensed gambling industry.
This report draws on data collected from April 1, 2023, to October 31, 2025, highlighting that both remote and non-remote casinos, along with betting activities, exhibit the highest risk profiles in the sector. In contrast, both the National Lottery and society lotteries were categorized as low-risk activities.
Data from the Commission revealed that between April 2024 and March 2025, remote casino gross gambling yield (GGY) reached £5 billion, primarily driven by slot games, which accounted for £4.2 billion. Remote betting generated £2.6 billion, while non-remote betting contributed £2.5 billion, with merely £28 million arising from on-course betting.
To assess risk, the Commission employed a methodology that utilized a formula combining likelihood and impact to evaluate sectors’ vulnerability to money laundering exploitation. Despite the national classification deeming casino TF risk as low, the Commission rated it as medium due to the severe implications associated with terrorist financing.
Peer-to-peer gambling products, including both poker and betting exchanges, were identified as having heightened ML risks, with poker categorized as having a “high” overall ML risk in both remote and non-remote casino contexts. Peer-to-peer betting also carries significant risks, especially in the remote betting arena. Furthermore, the gambling software sector has had its ML risk rating upgraded from low to medium, reflecting the cross-border challenges associated with software provision and the dangers of licensed software being misappropriated by unlicensed operators.
The report noted technical vulnerabilities, particularly in automatic ticket redemption systems and self-service betting terminals.
Payment methods emerged as critical risk factors; the Commission pointed out that the increased use of e-wallets, pre-paid cards, and funds linked to cryptoassets, especially in remote betting, could facilitate illicit activities. Complex payment systems that incorporate multiple payment methods or open-loop structures enhance the ability for illegal conduct.
Earlier in the year, the Commission created a taskforce aimed at investigating illegal gambling, focusing on payments made by online operators to support illicit operations. This taskforce is set to convene biannually over the next year.
A central issue in the report centered on the rising sophistication of criminal methods undermining customer due diligence. The tactics have evolved to include false documentation created using deepfake technology, face-swap videos, and various forms of AI-generated fraudulent identity materials.
The report pointed out that shortcomings on the operator side significantly exacerbate ML and TF risk. Across many subsectors, the Commission observed deficiencies in anti-money laundering (AML) and counter-terrorism financing (CTF) policies, alongside poorly trained staff. It also highlighted inadequately set AML thresholds and weak monitoring protocols for linked or duplicate accounts.
Specifically, the Commission indicated that a lack of scrutiny regarding white-label partnerships and business-to-business relationships poses a substantial risk. Notably, these white-label partnerships were untouched in the Department for Culture, Media and Sport (DCMS) consultation concerning the prohibition of unlicensed gambling sponsorships across sectors. This consultation aims to employ secondary legislation under the Gambling Act 2005 to criminalize promotion of unlicensed operators in Great Britain.
Concerns about the risks associated with casinos offering Money Service Business (MSB) functions, such as cheque cashing and foreign currency exchange, were also highlighted. By 2024, approximately 3% of remote casino licensees and 56% of non-remote licensees offered MSB services, with the Commission estimating MSB-related activity in casinos at around £70 million. Evidence of MSB-related money laundering includes multiple small foreign exchange transactions and dealings with jurisdictions deemed high-risk.
The assessment also detailed a notable rise in illegal gambling activities, particularly in unregulated casinos that often accept cryptoassets. An earlier analysis from the Commission pointed out growing challenges to data accuracy, heightened by the widespread adoption of anonymizing technologies like virtual private networks. Such illegal operations frequently serve as channels for organized crime and money laundering.
In response to these threats, the UK government has allocated £26 million over three years to the Gambling Commission to enhance efforts against illegal markets and address vulnerabilities associated with payment chains. Earlier this week, law enforcement arrested two individuals following a coordinated operation targeting an alleged illegal casino in Bristol.
