GC report warns of money-laundering risks in white-label oversight and P2P gambling

The Gambling Commission released its 2026 risk assessment on Thursday, covering money laundering (ML) and terrorist financing (TF) vulnerabilities across Britain's licensed gambling industry. Based on data from 1 April 2023 to 31 October 2025, the regulator kept remote and non-remote casinos and betting in the highest-risk category, while continuing to view the National Lottery and society lotteries as low risk.

Risk ratings and market scale

Between April 2024 and March 2025, remote casino gross gambling yield (GGY) hit £5 billion, with slots accounting for £4.2 billion. Remote betting produced £2.6 billion in GGY, and non-remote betting £2.5 billion, of which only £28 million came from on-course betting.

The Commission's methodology combines likelihood and impact into a risk rating for each sector. It set an overall medium TF risk for casinos despite the national assessment's low rating, citing the potentially serious consequences of a terrorist financing event. Peer-to-peer poker was given a high ML risk rating in both remote and non-remote settings, while peer-to-peer betting was flagged as high risk, especially in remote operations. Gambling software was also upgraded from low to medium ML risk due to the cross-border character of software supply and the danger of licensed products being resold to unlicensed operators.

Payments, technology and criminal methods

Payment-related risk is driven by the growing adoption of e-wallets, prepaid cards and crypto-linked funds, notably across remote channels, with open-loop or multi-method systems providing additional concealment. The report also identified technical vulnerabilities such as automatic ticket redemption in gaming machines and self-service betting terminals.

Fraud techniques are becoming more advanced, with false documentation now including deepfakes, face-swap videos and other AI-generated identity materials designed to undermine customer due diligence.

Operator failings and white-label oversight

Operator failures remain a significant contributor to ML/TF risk. The Commission cited inadequate AML/CTF policies and controls, poorly trained staff, incorrectly calibrated thresholds and weak supervision of linked or duplicate accounts. Weak scrutiny of white-label partnerships and other B2B relationships was also named a risk factor. White-label arrangements were not impacted by the DCMS consultation on banning unlicensed gambling sponsorships, which proposed secondary legislation under the Gambling Act 2005 to criminalise the promotion of unlicensed operators in Great Britain.

Money service business exposure

Casinos offering Money Service Business (MSB) functions, including foreign currency exchange and cheque cashing, pose particular concerns. In 2024, roughly 3% of remote casino licence holders and 56% of non-remote casino licence holders ran MSB services, estimated to involve around £70 million in activity. Indicators of MSB-linked money laundering include multiple small foreign-exchange transactions, exposure to high-risk jurisdictions and mismatched currency deposits and withdrawals.

Illegal gambling and enforcement

Illegal gambling has grown substantially, particularly among unregulated casinos that commonly accept cryptoassets and use anonymising tools such as VPNs. The Commission notes these outlets often act as conduits for organised crime, enabling both profit generation and money laundering. A taskforce created earlier this year will examine illegal gambling, with an emphasis on online operators' payment arrangements, meeting twice a year across a 12-month initiative. The UK government has committed £26 million over three years to the Commission for intensified action against illegal markets and payment chain vulnerabilities. Two individuals were arrested this week during a police operation targeting an alleged illegal casino in Bristol.