The Gambling Commission has released a 2026 risk assessment report on Thursday, evaluating money laundering (ML) and terrorist financing (TF) risks within the UK’s licensed gambling industry. The assessment, which encompasses data from April 1, 2023, to October 31, 2025, identifies both remote and non-remote casinos, as well as betting activities, as sectors with the highest risk profiles. This report holds significant weight for regulatory and business stakeholders, considering its implications for compliance and market stability.
The Commission’s methodology for assessing risks involved calculating a “likelihood x impact = risk” rating to determine the potential exploitation of each sector for money laundering. While the UK’s National Risk Assessment categorized the casino TF risk as low, the Gambling Commission designated it a medium risk due to the severe implications of any terrorist financing incidents. Notably, peer-to-peer gambling products like poker and betting exchanges were marked as high ML risks, reflecting their vulnerability both remotely and in physical casino settings.
Further, the report highlighted an increase in risk from gambling software, moving it from low to medium due to the cross-border nature of software supply and the possibility of software being sold to unlicensed operators. This shift underscores the need for robust international compliance measures.
In terms of payment methods, the rising use of e-wallets, prepaid cards, and cryptoasset-linked funds in remote gambling sectors were identified as significant risk factors, as these payment methods can facilitate anonymity and complicate regulatory oversight. The complexity of today’s payment systems, which often involve multiple methods or open-loop structures, poses additional challenges for anti-money laundering (AML) efforts.
The Commission has responded to these trends by forming a task force to investigate illegal gambling, focusing on payment mechanisms used by online operators. This task force will meet twice annually and is committed to a year-long initiative aimed at curbing illegal gambling activities.
Operator failings in AML and counter-terrorist financing (CTF) remain a concern, with the Commission identifying deficiencies in policies, controls, and staff training. Moreover, inadequate AML thresholds and poor account monitoring exacerbate these vulnerabilities. A particularly highlighted issue is the lack of scrutiny in white-label partnerships and business-to-business relationships, which contributes to potential risks.
White-label partnerships have, however, been left untouched in the Department for Culture, Media and Sport (DCMS)’s recent consultation on banning unlicensed gambling sponsorships, although plans to use secondary legislation under the Gambling Act 2005 to criminalize the promotion of unlicensed operators are underway.
The report also addressed the risks associated with casinos providing Money Service Business (MSB) functions, such as foreign exchange and cheque cashing. In 2024, a small percentage of remote and a majority of non-remote casino license holders offered MSB services, with related activities valued at approximately £70 million. Challenges include small transactions in foreign currency, interactions with high-risk jurisdictions, and mismatched currency deposits and withdrawals, all potential indicators of money laundering.
The growth of illegal gambling operations, particularly those accepting cryptoassets without regulation, poses a significant threat. These operations often serve as channels for organized crime, complicating efforts to ensure data accuracy due to anonymizing technologies like virtual private networks. In response, the UK government has allocated £26 million over three years to strengthen the Gambling Commission’s efforts against illegal gambling markets and associated vulnerabilities.
In recent developments, a police operation in Bristol led to the arrest of two individuals linked to an alleged illegal casino, underscoring the ongoing enforcement actions against unregulated gambling activities.
Looking forward, the next steps involve the continued commitment of the Gambling Commission to enforce stringent regulations and enhance oversight to mitigate money laundering and terrorist financing risks. This includes the anticipated implementation of new guidelines, regulatory reviews, and sustained market vigilance to adapt to emerging challenges in the gambling sector.
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