On Thursday, the Gambling Commission released its long-anticipated 2026 risk assessment report, scrutinizing money laundering (ML) and terrorist financing (TF) vulnerabilities within Britain’s licensed gambling sector.
The report, which encompasses data from April 1, 2023, to October 31, 2025, identifies remote and non-remote casinos, as well as betting activities, as having the highest risk profiles. In contrast, sectors like the National Lottery and society lotteries are regarded as low risk.
Data from the Commission indicates that between April 2024 and March 2025, the gross gambling yield (GGY) from remote casinos reached £5 billion, predominantly driven by slot games, which generated £4.2 billion. Meanwhile, remote betting yielded £2.6 billion, and non-remote betting produced £2.5 billion, with only £28 million stemming from on-course betting.
To assess risk, the Commission utilized a formula rating of likelihood multiplied by impact. This gauged the potential for money laundering exploitation specific to each sector. Although the nationwide National Risk Assessment categorized casino TF risk as low, the Commission designated it as a medium overall due to the severe repercussions associated with incidents of terrorist financing.
The report highlights peer-to-peer gambling products, such as poker and betting exchanges, as having heightened ML risks. The Commission classified poker with a “high” overall ML risk in both remote and non-remote casino contexts, while peer-to-peer betting also faced significant risks, especially in remote operations.
Additionally, the gambling software sector saw its risk classification increased from low to medium due to the cross-border supply nature and potential for licensed software to be resold or utilized by unlicensed operators. The report identified technical vulnerabilities, notably automatic ticket redemption systems in gaming machines and self-service betting terminals, as areas of concern.
Payment methods were emphasized as major risk components. The Commission noted the increasing adoption of e-wallets, pre-paid cards, and cryptoasset-related funds, particularly in remote sectors, where these methods can be exploited by criminals. The presence of complex payment systems with multiple methods offers further concealment opportunities for illicit activities.
Earlier this year, the Commission formed a taskforce to investigate illegal gambling prevalence, particularly focusing on online operators’ payment methods. This taskforce plans to convene biannually within a 12-month framework.
The report also underlines the growing sophistication of criminal tactics aimed at undermining customer due diligence. Criminals now employ advanced tools like deepfakes, face-swap videos, and AI-generated identity fraud materials.
Operator failures were identified as significant contributors to ML/TF risk, with the Commission citing inadequate AML/CTF policies, insufficiently trained staff, poorly defined AML thresholds, and ineffective monitoring of duplicate accounts.
A notable concern raised by the Commission is the insufficient scrutiny of white-label partnerships and business-to-business relationships, which are flagged as risk factors. White-label partnerships were not mentioned in the Department for Culture, Media and Sport (DCMS)’s recent consultation regarding unlicensed gambling sponsorship bans.
The consultation proposes utilizing secondary legislation under the Gambling Act 2005 to criminalize the promotion of unlicensed gambling operators in Great Britain.
The report further outlines risks associated with casinos acting as Money Service Businesses (MSB), such as engaging in foreign currency exchanges and cheque cashing services. Data revealed that in 2024, about 3% of remote casino license holders and 56% of non-remote license holders offered MSB services, with activity linked to MSB estimated at around £70 million.
Indicators of potential MSB-related money laundering include numerous small foreign-exchange transactions, operations with high-risk jurisdictions, and mismatches in currency deposits and withdrawals.
The assessment also noted a troubling surge in illegal gambling operations, especially unregulated casinos that are quick to accept cryptoassets and frequently operate outside of regulatory oversight. Earlier this year, the Commission highlighted challenges related to data integrity due to the rise in anonymizing technologies like virtual private networks, which these illegal establishments often exploit to facilitate organized crime and laundering activities.
In response to these challenges, the UK government has allocated £26 million over the next three years to the Gambling Commission to strengthen actions against illegal markets and address related payment vulnerabilities. Recently, two individuals were arrested in relation to a coordinated police operation targeting an alleged illegal casino in Bristol.
