Gambling Commission 2026 AML Risk Assessment Summary
The Gambling Commission have now released their updated AML Risk Assessment for 2026 highlighting new money laundering risks for the gambling sector. It is vital that all operators review the updates and amend their AML Risk Assessments respectively. This comes as a welcome update since the Commissions previous Anti-Money Laundering Risk Assessment released back in 2023 and follows the HM Treasury’s assessment which captures the relative risk of ML and TF occurring across all regulated financial sectors and Designated Non-Financial Businesses and Professionals (DNFBPs) (Operators should also take this into consideration).
Further down we have broken down the new risks from the ‘Gambling Commission AML Risk assessment 2026’ by sector as well as any changes, but Operators are still advised to read the updated risk assessment in full.
The commissions related website guidance can be found at;
https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/gambling-commission-money-laundering-risk-assessment-2026-published
This states that gambling operators should;
• consider how the risks outlined may apply to their businesses and update their risk assessments accordingly
• use the risk ratings provided to assist in assessing the level of risk posed to their businesses.
It further states that Casino licence holders must;
• consider how the risks outlined may apply to their business and update their risk assessment accordingly
• keep an up-to-date record of the steps taken to identify and assess money laundering and terrorist financing risks to their business.
Another note for Casino license holders is that there is an updated section on proliferation financing referring to the HM Treasury ‘National risk assessment of proliferation financing’ which should be considered. With examples of proliferation financing ‘red flags’ being;
• customers associated with casino junket tours where appropriate customer due diligence and enhanced customer due diligence cannot be completed
• use or attempted use of fraudulent documentation such as fake identity documents
• unusual numbers of cards or payment types being used on one account
• a customer IP address that is linked to multiple accounts
• suspicious activity in peer-to-peer gaming where the customer appears to make deliberate losses
• source of funds or wealth checks identify that customer funds are from the trade of ‘dual use goods’ with sanctioned states
• customer source of funds is crypto assets which have previously passed through a mixer
• customer is associated with a sanctioned state or individual.
Casino licence holders should review these risks within their proliferation financing risk assessment (or AML risk assessment if it is combined)
The commission have also put emphasis of illegal markets into the risk assessment, pointing operators to their website publication on illegal gambling.
If you have any questions on the Gambling Commission 2026 AML Risk Assessment updates, please do not hesitate to Contact Us
LINKS TO FULL DETAILS
Gambling Commission release HERE
The Gambling Commission AML risk assessment 2026 can be found HERE
The HM treasury AML risk assessment can be found HERE
The commissions new Risk Assessment release includes the below breakdown of the overall risk per sector as per the below:
| Sector | Overall risk |
| Casino, betting and bingo (remote) | High |
| Casino (non-remote) | High |
| Betting (non-remote, off course) | High |
| Betting (non-remote, on course) | Medium |
| Bingo (non-remote) | Medium |
| Adult Gaming Centres (AGCs) | Medium |
| Family Entertainment Centres (FECs) | Low |
| Society lotteries and external lottery managers (remote and non-remote) | Low |
| The National Lottery (remote and non-remote) | Low |
| Gambling software (remote and non-remote) | Medium |
| Gaming machine technical (remote and non-remote) | Low |
While all other sector risk ratings remain unchanged from previous years, it’s important to note that the risk Gambling software (remote and non-remote) has now increased to Medium.
It’s also noteworthy that “In the National Risk Assessment of Money Laundering and Terrorist Financing the casino sector risk rating has increased to medium” due to changes seen in customer, geographical and transaction risks since 2020.
To aid in your review we have listed the key changes and new risks by sector in the breakdown below to use as a practical reference when reviewing and updating your AML risk assessments to ensure it remains current and aligned with the commissions expectations.
Remote Casino
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Lack of adequate and relevant due diligence checks on customers who are not physically present for verification purposes | High (3) | High (3) | High (9) |
| Operator Control | Lack of appropriate customer risk profiling and ongoing monitoring | Medium (2) | High (3) | High (6) |
| Operator Control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Inappropriate controls relating to linked or duplicate accounts – this includes identifying linked accounts and, where multiple accounts are permitted, applying controls across accounts | High (3) | High (3) | High (9) |
| Customer | Customer linked to criminal activity | High (3) | High (3) | High (9) |
| Customer | Customer presents risks relating to their occupation – including access to third-party funds or funds originating from a cash intensive business | Medium (2) | Medium (2) | Medium (4) |
| Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) |
| Customer | Customer uses a third-party payment method that is not in their name | Medium (2) | High (3) | High (6) |
| Customer | Customer displays suspicious or unusual wagering patterns – such as withdrawing after minimal play | High (3) | High (3) | High (9) |
| Means of Payment | Casinos acting as Money Service Businesses (MSBs) | High (3) | High (3) | High (9) |
Changes to Existing Risks
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Updated Wording | Operator Control | Inappropriate AML thresholds – including thresholds that are not appropriate for the customer base or are predominantly loss based | High (3) | High (3) | High (9) |
| Decrease in Likelihood | Operator Control | High value customer schemes | Low (1) | High (3) | Medium (3) |
| Updated Wording | Operator Control | Inadequate due diligence on white label partnerships | High (3) | High (3) | High (9) |
| Updated Wording | Operator Control | Inadequate due diligence checks on business-to business relationships or business investors, resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) |
| Updated Wording | Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds – this includes the use of AI tools to generate documents or videos | High (3) | High (3) | High (9) |
| Decrease in Likelihood and Updated Wording | Customer | Customer gambles with multiple remote operators to disguise the source of their funds | Medium (2) | High (3) | High (6) |
| Decrease in Likelihood | Customer | Customers making numerous low – level transactions to minimise suspicion and evade CDD requirements at the threshold (smurfing) | Medium (2) | High (3) | High (6) |
| Updated Wording | Customer | Third party use of customer accounts to obscure the source of funds and identity of the user, including the creation of mule accounts and the use of agents | High (3) | High (3) | High (9) |
| Updated Wording | Geographic | Customers who are a resident of or are linked to high-risk jurisdictions using casino facilities to launder criminal funds | Medium (2) | High (3) | High (6) |
| Decrease in Likelihood | Means of Payment | Pre-paid methods including vouchers and cards – this payment method can make it difficult to identify the source of funds | Medium (2) | High (3) | High (6) |
| Updated Wording | Product | Poker – peer to peer gaming presents risks of collusion and the potential transfer of funds between customers | High (3) | High (3) | High (9) |
| Updated Wording | Product | High-stakes gambling on live casino games | Medium (2) | High (3) | High (6) |
Non-Remote Casino
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Inappropriate AML thresholds – including thresholds that are not appropriate for the customer base or are predominantly loss based | High (3) | High (3) | High (9) |
| Operator Control | Lack of appropriate customer monitoring – this includes the risk profiling and ongoing monitoring of customers in a business relationship, as well as the monitoring of customers where CDD has not been completed (for example under an open-door policy) | High (3) | High (3) | High (6) |
| Operator Control | Lack of closed-loop system | Medium (2) | High (3) | High (6) |
| Operator Control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | High (3) | High (6) |
| Customer | Customer presents risks relating to their source of income – including access to third party funds or funds originating from a cash intensive business | Medium (2) | Medium (2) | Medium (4) |
| Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) |
| Customer | Customer displays suspicious or unusual wagering patterns – such as minimal play and hedging bets | Medium (2) | High (3) | High (6) |
| Customer | Customer gambles at multiple premises or operators to disguise the source of their funds | Medium (2) | High (3) | High (6) |
| Customer | Customer linked to criminal activity | High (3) | High (3) | High (9) |
| Means of Payment | Terminals used to facilitate payments – funds received via this method may not be scrutinised as closely | Medium (2) | Medium (2) | Medium (4) |
| Means of Payment | Ticket-in-ticket-out (TITO) enabled machines used to launder criminal funds when used with an automatic ticket redemption (ATR) machine | Medium (2) | Medium (2) | Medium (4) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Updated Wording | Operator Control | MLRO lacks the independence and resources to uphold their responsibilities | Medium (2) | High (3) | High (6) |
| Updated Wording | Customer | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) |
| Increase in likelihood | Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds | High (3) | High (3) | High (9) |
| Decrease in likelihood | Customer | Customers breaking up large amounts of cash into small transactions to minimise suspicion and evade CDD requirements at the threshold (‘smurfing’) | Medium (2) | High (3) | High (6) |
| Updated Wording | Customer | Use of third parties to obscure the source or ownership of money gambled by customers -this includes agents and money mules | Medium (2) | High (3) | High (6) |
| Updated Wording | Geographic | Customers who are a resident of or are linked to high-risk jurisdictions using casino facilities to launder criminal funds | Medium (2) | High (3) | High (6) |
| Updated Wording | Means of Payment | Cash transactions – this includes the risk of dyed and counterfeit notes | High (3) | High (3) | High (9) |
| Updated Wording | Product | Poker – peer to peer gaming presents risks of collusion and the potential transfer of funds between customers | High (3) | High (3) | High (9) |
Betting (Remote)
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Lack of appropriate customer and transaction monitoring | Medium (2) | High (3) | High (6) |
| Operator Control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Inappropriate controls relating to linked or duplicate accounts – this includes identifying linked accounts and, where multiple accounts are permitted, applying controls across accounts | High (3) | High (3) | High (9) |
| Customer | Customer presents risks relating to their occupation – including access to third party funds or funds originating from a cash intensive business | Medium (2) | Medium (2) | Medium (4) |
| Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) |
| Customer | Customer uses a third-party payment method that is not in their name | Medium (2) | High (3) | High (6) |
| Customer | Customer displays suspicious or unusual wagering patterns – including placing large bets on ‘safe’ odds, betting on obscure markets or on events where the integrity has been called into question, as well as use of early ‘cash out’ features | Medium (2) | High (3) | High (6) |
| Customer | Customer linked to criminal activity | High (3) | High (3) | High (9) |
| Product | High-profile events – where there is a significant increase in betting activity there are increased transactions to monitor and previously unknown customers may place large bets | Medium (2) | High (3) | High (6) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Updated Wording | Operator Control | Inadequate ‘know your customer’ (KYC) measures on customers who are not physically present for verification – this includes the failure to obtain additional information following a risk-based approach | High (3) | High (3) | High (9) |
| Updated Wording | Operator Control | Inappropriate AML thresholds – including thresholds that are not appropriate for the customer base or are predominantly loss based | High (3) | High (3) | High (9) |
| Updated Wording | Operator Control | Pool betting operators staking and winning directly and indirectly on their own products | Low (1) | Medium (2) | Low (2) |
| Updated Wording | Operator Control | Inadequate due diligence on white-label partnerships | High (3) | High (3) | High (9) |
| Updated Wording | Operator Control | Inadequate due diligence checks on business-to business relationships or business investors resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) |
| Updated Wording | Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds – this includes the use of AI tools to generate documents or videos | High (3) | High (3) | High (9) |
| Updated Wording | Customer | Customer gambles with multiple remote operators to disguise the source of their funds | Medium (2) | High (3) | High (6) |
| Updated Wording | Customer | Third party use of customer accounts to obscure the source of funds and identity of the user – this includes the creation of mule accounts and the use of agents | High (3) | High (3) | High (9) |
| Decrease in Likelihood and Updated
Wording |
Customer | Customers making numerous low-level transactions to minimise suspicion and evade thresholds (smurfing) | Medium (2) | High (3) | High (6) |
| Updated Wording | Geographic | Customers who are a resident of or are linked to a high-risk jurisdiction using gambling facilities to launder criminal funds | Medium (2) | High (3) | High (6) |
| Decrease in Likelihood and Updated
Wording |
Means of Payment | Pre-paid methods including vouchers and cards – this payment method can make it difficult to identify the source of funds | Medium (2) | High (3) | High (6) |
| Updated
Wording |
Product | Peer to peer betting – there is a risk of the transfer of funds through betting exchange and small pool groups | High (3) | High (3) | High (9) |
Betting Non-Remote
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Lack of competence of key personnel and licence holders, which can then be exploited by criminals seeking to launder the proceeds of crime (off course) | Medium (2) | High (3) | High (6) |
| Operator Control | Lack of competence of key personnel and licence holders, which can then be exploited by criminals seeking to launder the proceeds of crime (on course) | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Lack of appropriate customer activity and transaction monitoring – this includes interactions with customers and monitoring play across different products (off course) | Medium (2) | High (3) | High (6) |
| Operator Control | Lack of appropriate customer activity and transaction monitoring. (on-course) | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Inappropriate AML thresholds – including thresholds that are not appropriate for the customer base or are predominantly loss based (off course and on-course) | Medium (2) | High (3) | High (6) |
| Operator Control | Failure to appropriately scrutinise source of funds documents (off course only) | Medium (2) | High (3) | High (6) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | High (3) | High (6) |
| Customer | Customer linked to criminal activity (off-course and-on course) | High (3) | High (3) | High (9) |
| Customer | Customer presents risks relating to their occupation – including access to third party funds or funds originating from a cash-intensive business (off course) | Medium (2) | Medium (2) | Medium (4) |
| Customer | Customer appears to be a disproportionate spender (off course) | Medium (2) | Medium (2) | Medium (4) |
| Customer | Customer gambles with stolen or fraudulent card (off-course and on-course) | Medium (2) | Medium (2) | Medium (4) |
| Product | High-profile events – where there is a significant increase in betting activity there are increased transactions to monitor and previously unknown customers may place large bets | Medium (2) | High (3) | High (6) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Decrease in Likelihood and Updated
Wording |
Operator Control | Inadequate know your customer (KYC) measures – including failure to obtain additional information following a risk-based approach (off-course) | Medium (2) | High (3) | High (6) |
| Updated
Wording |
Operator Control | Inadequate know your customer (KYC) measures – including failure to obtain additional information following a risk-based approach (on-course) | Medium (2) | Medium (2) | Medium (4) |
| Updated
Wording |
Operator Control | Lack of closed-loop system – where appropriate this includes consideration of transactions across channels and premises (off-course and on-course) | Medium (2) | High (3) | High (6) |
| Reduced Likelihood and Updated Wording | Customer | Customer gambles at multiple premises or operators to disguise the source of their funds (off-course and on course) | Medium (2) | High (3) | High (6) |
| Updated Wording | Means of Payment | Cash transactions – this includes the risk of dyed and counterfeit notes (off-course and on-course) | High (3) | High (3) | High (9) |
Bingo Remote
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Lack of competence of key personnel and licence holders which can then be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | High (3) | High (6) |
| Operator Control | Lack of appropriate customer and transaction monitoring | Medium (2) | High (3) | High (6) |
| Operator Control | Inappropriate AML thresholds – including thresholds that are not appropriate for the customer base or are predominantly loss based | Medium (2) | High (3) | High (6) |
| Operator Control | Failure to appropriately scrutinise source of funds documents | Medium (2) | High (3) | High (6) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Lack of closed loop system | Medium (2) | High (3) | High (6) |
| Operator Control | Inappropriate controls relating to linked or duplicate accounts – this includes identifying linked accounts and, where multiple accounts are permitted, applying controls across accounts | Medium (2) | High (3) | High (6) |
| Customer | Customer presents risks relating to their source of income – including access to third party funds or funds originating from a cash intensive business | Medium (2) | Medium (2) | Medium (4) |
| Customer | Customer appears to be a disproportionate spender | Medium (2) | High (3) | High (6) |
| Customer | Customer uses a third-party payment method that is not in their name | Medium (2) | High (3) | High (6) |
| Customer | Customer displays suspicious or unusual wagering patterns – such as withdrawal after minimal play | Medium (2) | High (3) | High (6) |
| Customer | Customer linked to criminal activity | Medium (2) | High (3) | High (6) |
| Geographic | Customers who are a resident of or are linked to a high-risk jurisdiction using gambling facilities to launder criminal funds | Low (1) | High (3) | Medium (3) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Updated Wording | Operator Control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Medium (2) | High (3) | High (6) |
| Increased likelihood and Updated wording | Customer | False or stolen identity documentation used to bypass controls to facilitate the laundering of criminal funds – this includes the use of AI tools to generate documents or videos | High (3) | High (3) | High (9) |
| Decreased likelihood and impact | Customer | Customer gambles with multiple remote operators to disguise the source of their funds | Low (1) | Medium (2) | Low (2) |
| Updated Wording | Means of Payment | Pre-paid methods including vouchers and cards – this payment method can make it difficult to identify the source of funds | Medium (2) | High (3) | High (6) |
Bingo Non-Remote
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Lack of competence of key personnel and licence holders which can then be exploited by criminals seeking to launder the proceeds of crime | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Lack of appropriate customer and transaction monitoring. This includes monitoring play on gaming machines, and across different products | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Lack of closed-loop system | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Premises converted from adult gaming centres (AGC) – these premises may have anonymous customers. | Medium (2) | Medium (2) | Medium (4) |
| Customer | Customer gambles at multiple premises or operators to disguise the source of their funds | Medium (2) | Medium (2) | Medium (4) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Updated Wording | Operator Control | Inadequate know your customer (KYC) checks conducted resulting in criminals laundering criminal proceeds – including failure to obtain additional information following a risk-based approach | Medium (2) | Medium (2) | Medium (4) |
| Updated Wording | Operator Control | Inadequate due diligence checks on business-to business relationships or business investors resulting in receipt of illicit funds | Medium (2) | Medium (2) | Medium (4) |
| Updated Wording | Means of Payment | Cash transactions – this includes the risk of dyed and counterfeit notes | Medium (2) | Medium (2) | Medium (4) |
| Increased Likelihood | Product | Gaming machines used to launder criminal funds | Medium (2) | Medium (2) | Medium (4) |
Arcades
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Inadequate ‘know your customer’ (KYC) measures – including failure to obtain additional information following a risk-based approach (AGC only) | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Lack of appropriate customer activity and transaction monitoring (AGC only) | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Lack of closed-loop system | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Medium (2) | Medium (2) | Medium (4) |
| Operator Control | Staff bonus schemes creating an incentive to overlook money laundering risks | Low (1) | Medium (2) | Low (2) |
| Customer | Customer gambles at multiple premises or operators to disguise the source of their funds | Medium (2) | Medium (2) | Medium (4) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Increased Likelihood | Operator Control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Medium (2) | Medium (2) | Medium (4) |
| Increased Likelihood | Operator Control | Lack of competence of key personnel and licence holders which can then be exploited by criminals seeking to launder the proceeds of crime (AGCs only) | Medium (2) | Medium (2) | Medium (4) |
| Decreased Likelihood | Operator Control | Lack of competence of key personnel and licence holders which can then be exploited by criminals seeking to launder the proceeds of crime (FECs only) | Low (1) | Low (1) | Low (1) |
| Updated Wording | Operator Control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds | Low (1) | Medium (2) | Low (2) |
| Updated Wording | Means of Payment | Cash transactions – this includes the risk of dyed and counterfeit notes | Medium (2) | Medium (2) | Medium (4) |
| Increased Likelihood | Means of Payment | Ticket-in-ticket-out (TITO) facilities used to launder funds when used in conjunction with ATR machines (AGCs only) | Medium (2) | Medium (2) | Medium (4) |
Remote and Non-Remote Society Lotteries and external lottery managers
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Lack of competence of key personnel and licence holders which can then be exploited by criminals seeking to launder the proceeds of crime | Low (1) | Medium (2) | Low (2) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Low (1) | Low (1) | Low (1) |
| Operator Control | Lack of closed-loop system | Low (1) | Low (1) | Low (1) |
| Means of Payment | Pre-paid entry, including gift cards for example lottery subscription gift cards | Low (1) | Medium (2) | Low (2) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Increased Impact | Operator Control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Low (1) | Medium (2) | Low (2) |
| Updated Wording | Operator Control | Inadequate know your customer (KYC) measures – including for customers who are not physically present | Low (1) | Low (1) | Low (1) |
| Increased Impact and Updated Wording | Operator Control | Inadequate due diligence checks on business-to-business relationships or business investors resulting in receipt of illicit funds. | Low (1) | Medium (2) | Low (2) |
| Increased Impact and Updated Wording | Means of Payment | Cash transactions – this includes the risk of dyed and counterfeit notes (non-remote only) | Low (1) | Medium (2) | Low (2) |
| Updated Wording | Licensing and integrity | Scratch cards or interactive instant win games | Low (1) | Low (1) | Low (1) |
| Updated Wording | Licensing and integrity | Operator links to organised crime result in laundering of criminal funds | Low (1) | Low (1) | Low (1) |
Remote and Non-Remote National Lottery
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Lack of competence of key personnel and licence holders which can be exploited by criminals seeking to launder the proceeds of crime | Low (1) | Medium (2) | Low (2) |
| Operator Control | Training for staff is insufficient and is not appropriately tailored | Low (1) | Low (1) | Low (1) |
| Operator Control | Lack of closed-loop system | Low (1) | Medium (2) | Low (2) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Increased Impact | Operator Control | National Lottery operator failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Low (1) | Medium (2) | Low (2) |
| Increased Impact | Licensing and integrity | National Lottery acquired by organised crime to launder criminal funds | Low (1) | High (3) | Medium (3) |
Remote and Non-Remote Gambling Software
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Operator Control | Insufficient monitoring of third-party contracts to identify the resale of software to unlicensed sites | Medium (2) | Medium (2) | Medium (4) |
| Means of Payment | Crypto asset transactions | Medium (2) | High (3) | High (6) |
| Geographic | B2B partner is based in or linked to a high-risk jurisdiction | Medium (2) | Medium (2) | Medium (4) |
| Licensing and Integrity | Gambling operations run or acquired by organised criminals to launder criminally derived funds | Low (1) | Medium (2) | Low (2) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Increased Impact | Operator Control | Operators failing to comply with prevention of money laundering and terrorist financing legislation and guidance | Low (1) | Medium (2) | Low (2) |
| Increased Impact, Likelihood and Updated wording | Operator Control | Inadequate due diligence checks on third party business relationships – including business to-business customers and test houses | Medium (2) | High (3) | High (6) |
| Increased Likelihood and Updated wording | Operator Control | Inadequate due diligence checks on business investors. | Medium (2) | Medium (2) | Medium (4) |
Remote and Non-Remote Gaming Machine Technical
New Risks:
| Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Licensing and integrity | Gambling operations run by organised criminals to launder funds | Low (1) | Medium (2) | Low (2) |
Changes to Existing Risks:
| Change | Vulnerability | Risk | Likelihood of Occurring | Impact | Overall Risk |
| Increased Impact | Operator Control | Inadequate due diligence checks on third parties, including customers and suppliers – this includes ensuring machines are only supplied to licensed premises | Medium (2) | Medium (2) | Medium (4) |
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