British Gambling Commission assessment flags casino terrorist financing risk level and white label concerns
The gambling regulator’s 2026 risk assessment raises the casino TF risk level to medium.
UK.- The British Gambling Commission has released its 2026 risk assessment on money laundering (ML) and terrorist financing (TF) vulnerabilities in the licensed gambling sector. Based on data from April 2023 to October 2025, the report assigns risk levels to different verticals and outlines key ML and TF risks and vulnerabilities in each.
The regulator notes that the risk landscape faced by licensed gambling operators continues to evolve as technology-driven advances, such as the rapid development in artificial intelligence capability, test the effectiveness of customer due diligence controls. It also warned that the growth of illegal gambling websites exposes operators to illicit financial flows in business-to-business relationships.
The report is intended to help inform the National Risk Assessment of Money Laundering and Terrorist Financing conducted by HM Treasury and the Home Office as well as the Gambling Commission’s own licensing, compliance and enforcement activity i
Gambling sector risk levels
According to the Gambling Commission, both remote and non-remote casinos, along with betting, continue to carry the highest risk profiles. By contrast, the National Lottery and society lotteries remain categorised as low risk. While the UK’s last National Risk Assessment of Money Laundering and Terrorist Financing classified casino TF risk as low, the Gambling Commission’s report flags it as medium.
Peer‑to‑peer gambling products such as poker and betting exchanges were flagged as particularly exposed. Poker was given a “high” ML risk rating in both remote and non-remote casino environments, while peer‑to‑peer betting was deemed high risk in remote settings.
The gambling software sector has been upgraded from low to medium ML risk, reflecting the cross‑border nature of supply chains and the danger of licensed software being resold to unlicensed operators. Technical vulnerabilities highlighted included automatic ticket redemption systems and self‑service betting terminals.
Payment methods remain a central concern. The regulator pointed to the growing use of e-wallets, pre-paid cards and cryptoasset-linked funds, particularly in remote gambling, as creating opportunities for illicit activity. Complex payment systems with multiple methods or open-loop structures were noted as offering concealment advantages to criminals.
The report also warned of increasingly sophisticated attempts to bypass customer due diligence, including the use of deepfakes, face-swap videos and other AI‑generated fraudulent identity materials.
Casinos offering Money Service Business (MSB) functions such as foreign currency exchange and cheque cashing were highlighted as vulnerable. In 2024, around 3 per cent of remote casino licence holders and 56 per cent of non-remote licence holders operated MSB services, with activity estimated at £70mn. Indicators of ML risk included multiple small foreign-exchange transactions, dealings with high‑risk jurisdictions and mismatched currency deposits and withdrawals.
White-label risks and illegal gambling threat
Operator shortcomings were identified as a major contributor to ML/TF risk. The Gambling Commission cited weak AML/CTF policies, poorly trained staff, inadequate thresholds and insufficient monitoring of linked accounts. White-label partnerships and business-to-business relationships were also flagged as risk factors, with the report noting “insufficient scrutiny” in these arrangements.
White-label partnerships were not restricted in the Department for Culture, Media and Sport’s recent consultation on banning unlicensed gambling sponsorships, but the consultation proposed secondary legislation under the Gambling Act 2005 to criminalise promotion of unlicensed operators.
The Gambling Commission also reported a rise in illegal gambling, particularly unregulated casinos accepting cryptoassets. These operations often act as conduits for organised crime, it warned.
Between April 2024 and March 2025, remote casino gross gambling yield (GGY) reached £5bn, with slot games contributing £4.2bn. Remote betting generated £2.6bn, while non-remote betting stood at £2.5bn, of which just £28m came from on-course betting. The Gambling Commission applied a “likelihood x impact = risk” formula to assess vulnerabilities.
The Gambling Commission is currently stepping up its enforcement activity against unlicensed gambling supported by a new £26m in funding over the next three years. The regulator is also part of the Department for Culture, Media and Sport’s new Illegal Gambling Taskforce, which is chaired by Baroness Fiona Twycross, the Minister for Museums, Heritage and Gambling, and also features a mix of experts and industry participants from the gambling sector, tech platforms and payment providers alongside government departments and trade bodies.
