The Gambling Commission released a comprehensive risk assessment on Thursday that reviews money laundering (ML) and terrorist financing (TF) vulnerabilities in the UK’s licensed gambling sector, focusing on data from April 1, 2023, to October 31, 2025.
The report identifies remote and non-remote casinos, along with various betting activities, as the sectors with the highest risk profiles, while areas like the National Lottery and society lotteries are deemed low risk.
From April 2024 to March 2025, the gross gambling yield (GGY) for remote casinos reached £5 billion, with slot games contributing £4.2 billion. Remote betting brought in £2.6 billion, and non-remote betting was slightly lower at £2.5 billion, with only £28 million generated from on-course betting.
The Commission used a formula of likelihood multiplied by impact to assess risk across different gambling sectors. Despite a low classification of TF risk within the National Risk Assessment, the Commission categorized the overall TF risk for casinos as medium due to the severe consequences of potential incidents.
Peer-to-peer gambling products, such as poker and betting exchanges, were highlighted as having elevated ML risks, with poker rated as high risk in both remote and non-remote settings. Similarly, peer-to-peer betting exhibits high ML risks, especially in remote environments. Furthermore, the gambling software sector has moved from a low to medium ML risk status, largely owing to the cross-border dynamics of software distribution, which raises the potential for licensed software to be misused by unlicensed operators.
Additionally, technical vulnerabilities were identified, including automatic ticket redemption systems in gaming machines and self-service betting terminals, which may expose operators to greater risks.
Payment methods emerged as significant risk factors, with the Commission noting an increase in the usage of e-wallets, pre-paid cards, and cryptoasset-linked funds, particularly in remote sectors, thus providing increased opportunities for illicit activities. Highly complex payment systems that incorporate multiple methods also contribute to criminal concealment.
Earlier this year, the Commission established a taskforce dedicated to investigating illegal gambling activities. This taskforce will specifically focus on the payments made by online operators to facilitate their operations and is set to convene biannually for the next 12 months.
A key concern highlighted in the report is the growing sophistication of criminal tactics aimed at circumventing customer due diligence processes. For instance, the use of false documents has evolved to include deepfakes and AI-generated identity materials.
Operator failures were identified as a significant contributor to ML and TF risks, with the Commission observing insufficient AML and CTF policies alongside inadequately trained staff across several sectors. Also noted were poorly set AML thresholds and weak monitoring practices for linked or duplicate accounts.
The report particularly pointed to the lack of scrutiny surrounding white-label partnerships and B2B relationships as notable risk factors. Interestingly, these partnerships were not addressed in the Department for Culture, Media and Sport (DCMS)’s recent consultation concerning a ban on unlicensed gambling sponsorship.
In terms of financial operations, risks associated with casinos providing Money Service Business (MSB) functions were also addressed. Around 3% of remote casino licence holders and 56% of non-remote holders engaged in MSB services in 2024, with MSB-related casino activity estimated at approximately £70 million. Indicators of money laundering linked to MSB include numerous small foreign exchange transactions and dealings with high-risk jurisdictions.
The report also detailed a significant uptick in illegal gambling activities, especially involving unregulated casinos that accept cryptoassets without oversight. These operations pose serious challenges to data accuracy due to the increased use of anonymizing technologies, such as virtual private networks, and often facilitate organized crime and money laundering.
In a bid to combat these issues, the UK government has allocated £26 million to the Gambling Commission over three years to strengthen efforts against illegal markets and the associated risks in payment chains. Recently, two individuals were arrested during a coordinated operation aimed at an alleged illegal casino in Bristol.
