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Gambling Commission’s Risk Assessment Highlights Money Laundering Threats

by Sienna Marques
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Gambling Commission's Risk Assessment Highlights Money Laundering Threats

On Thursday, the Gambling Commission published its long-anticipated 2026 risk assessment report, which focuses on vulnerabilities related to money laundering (ML) and terrorist financing (TF) within Britain’s licensed gambling industry.

The report analyzes data from April 1, 2023, to October 31, 2025, highlighting that remote and non-remote casinos, alongside various betting activities, present the highest risk profiles. In contrast, sectors like the National Lottery and society lotteries are still viewed as low risk.

From April 2024 to March 2025, gross gambling yield (GGY) figures showed that remote casinos generated £5 billion, with slot games alone contributing £4.2 billion. Remote betting reported figures of £2.6 billion, while non-remote betting accounted for £2.5 billion, with only £28 million generated from on-course betting.

The Commission's methodology involved a calculation formula—"likelihood x impact = risk"—to evaluate the risk associated with each sector. Although the National Risk Assessment categorizes the casino TF risk as low, the Commission classified it as a medium risk overall due to the potentially serious consequences of terrorist financing incidents.

Among the findings, peer-to-peer gambling products, such as poker and betting exchanges, were identified as significant ML risks. Poker was rated with a “high” ML risk in both remote and non-remote settings, and remote betting platforms were also deemed to carry high risks.

The gambling software sector's risk status was raised from low to medium, reflecting the international nature of software supply and the associated risk of licensed platforms being resold or provided to unlicensed operators. Furthermore, technical vulnerabilities were flagged, including automatic ticket redemption systems in gaming machines and self-service betting terminals.

Payment methods emerged as another major risk factor. The increasing use of e-wallets, prepaid cards, and cryptocurrency-linked funds in remote sectors poses greater opportunities for malicious activity, particularly through complex payment systems that obscure financial transactions.

Earlier this year, the Gambling Commission initiated a taskforce to study illegal gambling's prevalence, aiming to scrutinize specific payments made by online operators. This taskforce will meet biannually over the next 12 months.

A significant theme in the report involves the growing sophistication of criminal methods that compromise customer due diligence. Fraudulent tactics now include deepfakes and AI-generated identity materials.

The report outlines difficulties operators face, pointing out that inadequate anti-money laundering (AML) and counter-terrorism financing (CTF) policies, along with poorly trained personnel, contribute to heightened risks. It emphasized the shortcomings in monitoring linked or duplicate accounts and noted that insufficient scrutiny of white-label partnerships exacerbates these risks.

Despite white-label partnerships remaining unaffected in the Department for Culture, Media and Sport’s (DCMS) recent consultation on banning unlicensed gambling sponsorships, the Commission underscores their potential dangers.

The report also underlined the risks linked to casinos that offer Money Service Business (MSB) services such as currency exchange and cheque cashing. Data from 2024 indicates that around 3% of remote and 56% of non-remote casino license holders provided MSB services, with estimated activity reaching approximately £70 million. Signs of MSB-related money laundering often include multiple small foreign-exchange transactions and dealings with high-risk jurisdictions.

Highlighting a growing threat, the assessment noted a substantial rise in illegal gambling, particularly within unregulated casinos accepting cryptocurrencies without oversight. These operations frequently utilize anonymizing technologies, complicating accurate data collection and providing avenues for organized crime to launder proceeds.

In response to these challenges, the UK government has allocated £26 million over three years to enhance the Gambling Commission's efforts against illegal markets and address payment chain vulnerabilities. Recently, law enforcement arrested two individuals following a targeted operation against an alleged illegal casino in Bristol.

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