UK Law and Practice Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan
The emerging risks are expected to be considered by operators when conducting their money launder- ing, terrorist and proliferation financing risk assess- ments. In July 2025, HM Treasury published an updated National Risk Assessment, which – notably – increased the money laundering risk of casinos from “low” to “medium”. In October 2025, the Gambling Commission updated its casino AML guidance to include changes to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and changes to POCA, as well as the Gambling Com- mission’s expectation that operators must give due consideration to money-laundering risks posed by their business-to-business relationships. Tax The Labour government’s budget announced on 30 October 2024 did not increase UK gambling taxes. However, the government plans to reform, consolidate and simplify the current structure for remote gambling. At the time of writing, it is expected that the Labour government’s Autumn Budget (to be delivered on 26 November 2025) will increase UK gambling taxes. Personal Accountability of Management On 29 November 2024, Licence Condition 1.2.1 of the LCCP was amended to clarify and increase personal management licence (PML) coverage. The changes include: • adding wording to state that the individual who holds responsibility for the overall management and direction of the licensee’s business is likely the CEO, managing director, or equivalent; • the chairperson of the board (where applicable) must hold a PML; and • the person responsible for the licensee’s AML/CFT function as head of that department must hold a PML. 2. Jurisdictional Overview 2.1 Online Gambling The following online sectors are regulated in Great Britain:
• betting (live, in-play, fixed-odds and pari-mutuel, betting exchanges, and intermediaries); • bingo; • casino; • fantasy sports;
• gaming machines; • gambling software; • lotteries; and • poker.
Free-to-play social gaming is not regulated. The Gam- bling Commission concluded, following a scoping review in 2015, that the sector did not require regula- tion but would continue to be monitored by the Gam- bling Commission for any potential risks. Please refer to 2.2 Land-Based Gambling for product definitions. 2.2 Land-Based Gambling The following land-based sectors are regulated in Great Britain. • Arcades – for arcades, each arcade category can offer a specific subcategory of gaming machine. Those under 18 years of age may not be allowed access to the adult-only section of a licensed fam- ily entertainment centre or an adult gaming centre. Arcades can be divided into three categories: (a) adult gaming centres; (b) licensed family entertainment centres; and (c) unlicensed family entertainment centres. • Betting (live, in-play, fixed-odds and pari-mutuel, betting exchanges, and intermediaries) – see 3.2 Definition of Gambling for a definition of betting. • Bingo – this is not defined in UK legislation; howev- er, the Gambling Commission has published guid- ance stating that bingo constitutes “equal chance” gaming. For further guidance, please refer to the Gambling Commission’s website. • Casino – this constitutes arrangements providing people an opportunity to participate in one or more casino games. “Casino game” means a game of chance that is not equal-chance gaming. • Fantasy sports – this is not defined in the 2005 Act, but the Gambling Commission has issued guid- ance on its website regarding this product.
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