The Gambling Commission released its long-awaited risk assessment report on Thursday, examining money laundering (ML) and terrorist financing (TF) vulnerabilities in Britain’s licensed gambling sector from April 2023 to October 2025.
The report identified remote and non-remote casinos, along with betting activities, as having the highest risk profiles, while sectors like the National Lottery and society lotteries remained categorized as low risk.
For the period from April 2024 to March 2025, the Commission reported that the gross gambling yield (GGY) for remote casinos reached £5 billion, with slot games generating £4.2 billion. Remote betting accounted for £2.6 billion, whereas non-remote betting yielded £2.5 billion, with only £28 million coming from on-course betting.
To assess risk, the Commission utilized a formula that factors in likelihood and impact. Although the National Risk Assessment objectively rated casino TF risk as low, the Commission deemed it a medium risk overall due to the serious implications of potential terrorist financing incidents.
Peer-to-peer gambling activities, including poker and betting exchanges, were highlighted as having elevated ML risks, with poker assigned a “high” ML risk classification in both remote and non-remote settings. Similarly, remote betting platforms presented high risks as well.
The gambling software sector's risk level was raised from low to medium, reflecting the dangers posed by the cross-border nature of software distribution and the possibility of licensed software being sold to unlicensed entities.
The report pointed out that technical vulnerabilities exist too, particularly in automatic ticket redemption systems for gaming machines and self-service betting terminals.
Payment methods were identified as significant contributors to ML risks. The report emphasized the increasing use of e-wallets, prepaid cards, and crypto-linked funds in remote sectors, as these methods can facilitate illicit activities. Complex payment systems that combine various methods further complicate monitoring efforts.
Earlier this year, the Commission initiated a taskforce to investigate illegal gambling, specifically examining online operators' payment practices. The taskforce plans to convene biannually over the next year.
A key concern noted in the report was the growing sophistication of criminal strategies that undermine customer due diligence, including the use of fake documents and advanced AI-generated identity manipulation.
Operator deficiencies have been identified as significant contributors to ML and TF risks. The Commission detected inadequate anti-money laundering (AML) and counter-terrorist financing (CTF) policies, as well as insufficiently trained staff across various subsectors. Problems included improperly set AML thresholds and weak monitoring of linked or duplicate accounts.
The Commission expressed particular concern regarding the lack of scrutiny surrounding white-label partnerships, which have been flagged as a notable risk factor. Recently, these partnerships were not criticized in a consultation by the Department for Culture, Media and Sport (DCMS) regarding a ban on unlicensed gambling sponsorships across sectors.
This consultation proposed using secondary legislation under the Gambling Act 2005 to criminalize the promotion of unlicensed operators in Great Britain.
The report also delved into the risks associated with casinos that offer Money Service Business (MSB) functions, such as currency exchange and cheque cashing. In 2024, 3% of remote casino license holders and 56% of non-remote license holders provided MSB services, with an estimated £70 million linked to MSB activities in casinos.
Indicators of MSB-related money laundering included multiple small transactions, especially with high-risk countries, and discrepancies between currency deposits and withdrawals.
The assessment highlighted a notable increase in illegal gambling activities, primarily in unregulated casinos that often accept cryptocurrencies. The Commission’s earlier analysis suggested emerging data accuracy challenges due to the use of anonymizing technologies like virtual private networks.
Such illegal operations not only generate proceeds but also facilitate money laundering for organized crime.
In response, the UK government has allocated £26 million over three years to the Gambling Commission to strengthen measures against illegal markets and address vulnerabilities in payment chains. Recently, police arrested two individuals following a coordinated effort against an alleged illegal casino in Bristol.
