Lack of white-label partnerships scrutiny is a money laundering risk, reports GC

The Gambling Commission on Thursday published a long-awaited 2026 risk assessment report evaluating money laundering (ML) and terrorist financing (TF) vulnerabilities across Britain’s licensed gambling industry. 

Drawing on data from 1 April 2023 to 31 October 2025, Thursday’s report maintained that remote and non-remote casinos alongside betting activities, remained the subsectors with the highest risk profiles. 

While other areas such as the National Lottery and society lotteries continued to be considered low risk.

Between April 2024 to March 2025, comission data showed remote casino gross gambling yield (GGY) reached £5 billion, with slot games accounting for £4.2 billion.

Remote betting yielded £2.6 billion while non-remote betting was £2.5 billion (with only £28 million from on-course betting).

Methodology and risk

To determine risk, the commission’s methodology included a likelihood “x impact = risk” rating formula. Risk factors were measured against how high a potential money laundering exploitation was to each individual sector.

Although the nationwide National Risk Assessment classified the casino TF risk as low, the Commission assigned it as a medium TF risk overall due to the potentially severe consequences of terrorist financing incidents. 

Peer-to-peer gambling products, including poker and betting exchanges, were singled out as heightened ML risks. The Commission assigned poker a “high” overall ML risk in both remote and non-remote casino environments. Peer-to-peer betting similarly carries high risks, particularly in remote betting.

The gambling software sector has been upgraded from low to medium ML risk. This adjustment, according to the report, reflected the cross-border nature of software supply and the risk of licensed software being resold or supplied to unlicensed operators.

Technical vulnerabilities identified also included automatic ticket redemption systems in gaming machines and self-service betting terminals.

Scale and payment trends underpin risks

Payment methods are highlighted as significant risk factors. The commission emphasised the rising use of e-wallets, pre-paid cards and cryptoasset-linked funds, especially in remote sectors, as these present greater opportunities for nefarious activity. 

Complex payment systems incorporating multiple methods or open-loop structures add further concealment advantages for criminals.

Earlier this year, the commission established a taskforce to investigate the prevalence of illegal gambling. It will focus on the specific payments of online operators to facilitate operations. The taskforce will meet twice a year, committed to a 12-month initiative.

A central theme of the report was the escalating sophistication of criminal techniques aimed at undermining customer due diligence. The use of false documentation has evolved to include deepfakes, face-swap videos and other AI-generated fraudulent identity materials.

Operator failings and white-label partnerships

Operator-side failings remained a major contributor to ML/TF risk. Across multiple subsectors, the Commission noted deficient AML/CTF policies and controls as well as poorly trained personnel.

The report also noted the inadequate or improperly set AML thresholds and the weak monitoring of linked or duplicate accounts.

Notably, the Commission reported that insufficient scrutiny of white-label partnerships and business-to-business relationships were a risk contributor. 

White-label partnerships recently came out unscathed in the Department for Culture, Media and Sport (DCMS)’s consultation on the ban of unlicensed gambling sponsorships across all sectors. 

The consultation outlined plans to use secondary legislation under the Gambling Act 2005 to criminalise the promotion of unlicensed gambling operators in Great Britain. 

Money Service Business woes

The report noted the risks linked to casinos providing Money Service Business (MSB) functions, such as foreign currency exchange and cheque cashing. 

In 2024, around 3% of remote casino licence holders and 56% of non-remote casino licence holders operated MSB services. The Commission estimated MSB-related casino activity at approximately £70 million.

Indicators of MSB-related money laundering include multiple small foreign-exchange transactions, dealings with high-risk jurisdictions and mismatched currency deposits and withdrawals.

Growing threat from illegal gambling

The assessment detailed a significant rise in illegal gambling activity, particularly across unregulated casinos operating without oversight and frequently accepting cryptoassets. The Commission released an analysis earlier this year that highlighted emerging challenges to data accuracy due to the increased use of anonymising technologies, such as virtual private networks. 

These illegal operations often serve as conduits for organised crime, facilitating both proceeds generation and money laundering. 

The UK government has allocated £26 million over three years to the Gambling Commission to intensify actions against illegal markets and address associated payment chain vulnerabilities. 

Earlier this week, two individuals were arrested following a coordinated police operation targeting an alleged illegal casino in Bristol.