John Pierce, British Gambling Commission: “Regulatory failures carry significant consequences”
John Pierce, Director of Enforcement and Intelligence at the British Gambling Commission, spoke with Focus Gaming News about compliance, AML challenges, emerging threats and efforts to combat illegal gambling.
Exclusive interview.- In the last few months, the British Gambling Commission has stepped up enforcement actions, introduced stricter AML oversight, and expanded disruption efforts against illegal gambling. To better understand what these changes mean for operators, Focus Gaming News sat down with John Pierce, director of enforcement and intelligence.
The Gambling Commission has issued some headline-grabbing financial settlements in recent years. Do you think these have helped make operators pay more attention to compliance?
Yes, the financial penalties issued in recent years have had a notable impact on how operators approach their compliance obligations, but this is only one aspect of case outcomes. Increasingly, we have seen the need to add in license conditions such as a third-party audit and board oversight to get added assurance that policies and procedures in place are operationally effective. These cases have served as a clear reminder that regulatory failures carry significant consequences, and they’ve prompted many in the industry to re-evaluate and strengthen their internal controls.
But our approach is not just about enforcement. In our Corporate Strategy, we identified being proactive and addressing issues at the earliest opportunity as a strategic priority. That’s why we’re working closely with the industry – through educational initiatives, updated guidance, and engagement events such as the Gambling Commission Operator Engagement Forum – to share best practice, deal with issues effectively and seek to reduce reliance on formal enforcement action where appropriate to do so. This further builds on existing processes, such as the use of our Special Measures process to achieve Compliance at the earliest opportunity.
We are starting to see signs that these efforts are having an effect, with growing collaboration and discussions with Industry about operational matters to promote best practice. Whilst these are positive developments, continued focus and effort is needed to ensure lasting progress is made and the required regulatory standards are maintained.
Despite improvements in AML processes and procedures, do you think some operators still lack an understanding of what’s expected in this area, particularly in how to read sources of funds information?
There have been enforcement cases where we have identified that some operators have not appropriately scrutinised source of funds information in practice, and other cases where source of funds information has not been sought either early enough in the customer journey or on an adequate risk basis.
In relation to AML, one of the key aspects for operators is to ensure that money laundering risks associated with their business are identified through their risk assessment, with robust policies in place to intervene when risks increase. The risks identified then have to be mitigated through appropriate policies, procedures and controls, ensuring appropriate procedures are implemented effectively, including staff training. Ensuring that detailed records are maintained when decisions are reached concerning potential AML/CTF concerns is fundamental and is an area we have asked some operators to reflect on. Frequent staff training alongside adequate controls is a critical line of defence that should be implemented and regularly reviewed for effectiveness, taking into account any regulatory changes or updates.
Where we see AML issues presented in enforcement cases, it is typically due to a breakdown in some part of that process of risk assessment, or a failure to implement appropriate and effective policies, procedures and controls that stand up to scrutiny when tested. An over-reliance on algorithms to monitor behaviour also creates added risks if they are not found to be working effectively when tested in practice. Operators should also be mindful of risks associated with any payment systems they adopt, particularly concerning digital vouchers, for example. In broad terms, however, we are seeing an improvement in the quality of AML/CTF controls being applied on a risk-based basis across the various industry sectors, but again, it’s important that strict AML/CTF regulatory standards are maintained.
What are the most concerning new threats emerging, and how can operators ensure they are alert against them?
In relation to emerging risks in AML practices, in April 2025, the Commission released its latest publication, which highlighted numerous emerging risks in relation to tackling Money Laundering in the sector. For example, the risks around money service business activity, like foreign currency exchange, the use of Artificial Intelligence to bypass due diligence checks, and open-loop payment processes.
The publication raises awareness of these risks and outlines what operators need to do to address each risk. In general, operators should review and update their risk assessment, and consider if updates to their policies, procedures and controls are required. Where updates are made, operators must train their staff and monitor the effectiveness of the updates. Emerging new payment methods and platforms are developing quickly in response to customer demands; these present their own challenges in terms of effective AML policies and, more broadly, ensuring that consumers are protected from harm.
Alongside this, we have been undertaking work to tackle illegal market activity, including test purchasing activity. As a direct result of this work we released a notification to all licensed B2B Operators to warn them about the presence of licensed games present in the illegal market place, to remind them of their licensing obligations and to ensure that their supply chain is robust and fully auditable; and any presence of their games in the illegal market space will naturally raise Money Laundering concerns. We have a robust approach to tackling illegal markets activity and set clear expectations for our licensed B2B Operators to ensure that their products are not available on unlicensed sites targeting GB consumers.
I would like to see regular publications such as this being released to support the industry and raise awareness of emerging threats we identify through the course of our operational work. Feedback from the Industry has been really positive in relation to the emerging threats publication, and as a result, further updates are planned to take place later this year.
“Operators should review and update their risk assessment, and consider if updates to their policies, procedures and controls are required.”
John Pierce, director of enforcement and intelligence at British the Gambling Commission.
There remains some controversy over white-label arrangements. Would you welcome a review of regulations in this area?
The previous government’s conclusion on white labels was outlined in their 2023 White Paper.
Our LCCP makes clear that licensees have responsibility for third parties that they contract with. It also requires licensees to ensure that any contracted third parties conduct themselves in so far as they carry out activities on behalf of the licensee, as if they were bound by the same licence conditions and subject to the same codes of practice as the licensee.
We expect all operators to carry out due diligence on any third parties they engage with; if not, there will be significant consequences. The link to sponsorship arrangements, too, needs careful management, and we do test controls to ensure that our licensing requirements have been met.
In May, we took action against TGP Europe following failures in not carrying out sufficient checks on business partners and breaching anti-money laundering rules. The existing regime has worked well to tackle failures we have identified.
“We expect all operators to carry out due diligence on any third parties they engage with; if not, there will be significant consequences.”
John Pierce, director of enforcement and intelligence at British the Gambling Commission.
We hear a lot about enforcement actions for the regulated market. How about unlicensed operators? Does the Commission have concerns about the extent of black-market gambling and how effective do you think current powers are to tackle unregulated offerings?
Our aim is to prevent the illegal market from operating at scale in Great Britain; the Gambling Commission has a dedicated investigation team responsible for tackling and disrupting illegal gambling activity. Whilst we have made significant progress, including introducing a team to support our disruption, test purchasing and investigation capability, we recognise that this area moves at pace and frequently adapts.
A significant part of our strategy is to target our efforts upstream, working with technology platforms, including search engines and payment providers, to disrupt the unlicensed market.
Since April 2024, we have issued over 2,001 Cease and Desist and disruption notices, including 1,254 Legal notices issued to websites either offering or advertising to Great British consumers. As well as this, over 238,927 URLs have been referred for removal to Google and Bing, with 131,335 URLs being removed from results by search engines. Alongside this, our test purchasing activity means that we can now report payment facilities associated with illegal gambling to Visa, and anticipate that this will be extended to Mastercard shortly. We are also working with key law enforcement colleagues to react to financial intelligence associated with illegal gambling activity to target financial accounts associated with such activity.
We’re also working closely with other regulators around the world, through IAGR, we’ve created the Illegal Gambling Working Group, and we are active in signing Memorandum of Understandings with other regulators to support information sharing opportunities. We are already starting to see referrals internationally and will be working side-by-side with another Regulatory regulator in September to share best practices and learn more about the impact of illegal websites cross border. Engagement with key domain providers, such as Nominet, to identify and refer illegal gambling websites adds a further layer to our disruption strategy.
Alongside referring illegal content to online providers such as Meta, X and TikTok, we will now be making legal information requests where applicable to obtain further information on those responsible for both advertising and offering illegal gambling, with further action possible for any individual based within Great Britain. The information obtained from such requests will also assist in the collection of data on the individuals involved in illegal sites and may allow actions to be taken elsewhere in the world through our collaboration with overseas regulators.
Our enforcement actions in this area are not solely limited to online activity; following an investigation by the Gambling Commission Enforcement Team; in March 2025 a 39 year old male was charged with providing facilities for gambling to consumers in Great Britain without holding an operating licence between October 18, 2023 to September 11, 2024, and advertising those facilities between May 26, 2023 and March 1, 2024. The team are also leading on criminal investigations associated with sports betting integrity issues.
Whilst progress has been made, most of our existing disruption activity relies on collaboration with partners, major tech companies and advertisers; future proposals to provide additional powers to support our work in tackling online illegal markets will be a positive step forward but collaboration, knowledge-building, awareness, education, intelligence sharing and early identification of illegal markets risks will remain core elements of our response.
We recognise that whilst the true scale of the illegal gambling marketplace is difficult to assess, it is present and our work in this space continues to grow. We strongly encourage members of the public, operators, other regulators and law enforcement to engage with the Gambling Commission about any concerns they have about illegal markets activity. This can be reported via our confidential portal, which is available on our website; operators also have other channels they can use to report any concerns directly to our intelligence team.
Finally, some operators have faced fines for failing to meet deadlines for regulatory returns under the new quarterly calendar. Do you think this was mainly due to oversight/a failure to adapt processes, and do you expect operators will now comply with the new calendar?
Overall, the move from annual to quarterly reporting has happened smoothly. However, as we’ve shown with our recent enforcement bulletin, whilst we will provide support and guidance to operators in the first instance, repeated failures by operators in completing their regulatory returns will lead to regulatory action. The delayed reporting issues have primarily impacted smaller operators.
Since October, we’ve fined 16 businesses a total of over £9,000 for continued failures in relation to submissions of their regulatory returns, including a failure to meet necessary reporting deadlines. This is despite early engagement and advice being issued in the first instance. We expect all licensees to understand their reporting obligations and ensure that their returns are submitted on time.
We’ll continue to engage with licensees to ensure compliance and very much see enforcement activity as a last resort only. Following engagement with the Industry, we have seen real improvements in the timeliness of submissions.
