2017 ML/TF risk assessment of the British gambling industry

The Gambling Commission has today published its Money laundering and terrorist financing risk assessment 2017 highlighting the core and emerging risks associated with each of the gambling sectors within the British licensed gambling industry.

The Commission intends that this risk assessment (that can be downloaded below) should “act as a valuable resource for the industry in informing their own ML/TF risk assessments”.

The overall risk ratings have not changed since the previous risk assessment, published in March 2017, i.e:

  • Arcades (non-remote): Medium
  • Betting (non-remote): Higher
  • Bingo (non-remote): Medium
  • Casinos (non-remote): Higher
  • Gaming machines (remote and non-remote): Lower
  • Lotteries (remote and non-remote): Lower
  • Remote (casinos, betting and bingo): Higher

However, the Commission is keen to emphasise that the gambling industry is not immune to ML/TF, saying:

  • “it is highly segmented, with a wide range of operators based both domestically and overseas, offering diverse products, in different environments, to different types of customers, with various payment methods”,
  • “criminals are increasingly looking for alternative ways to launder criminal proceeds and the gambling industry needs to be alert to this”,
  • it expects “all operators to have an awareness of the vulnerabilities, controls and consequences associated with the ML/TF risks in gambling” and
  • “it is imperative that gambling operators comply with the requirements of the Gambling Act 2005 (the Act) and the Licence Conditions and Codes of Practice (LCCP) to ensure that they have effective policies, procedures and controls in place to prevent ML/TF, and continue to raise standards in that regard”.