UK Law and Practice Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan
Money-laundering offences are outlined in POCA and TACT. The exemption threshold for paying away funds when exiting a relationship with a customer was increased from GBP1,000 to GBP3,000 in July 2025. The Gambling Commission has also issued guid- ance for casinos – and, separately, for non-casinos – regarding their duties and responsibilities under POCA. The Gambling Commission most recently updated its guidance for casinos in October 2025 to incorporate: • requirements concerning the treatment of domestic PEPs; • changes to the list of high-risk third countries; • updates to POCA; and • the requirement for operators to give consideration to money-laundering risks posed by their business relations. 8.2 AML Requirements See 8.1 AML Legislation . The AML requirements are complex and cannot be adequately summarised here, particularly given the Gambling Commission’s ongo- ing focus and extensive casework in this area. Gener- ally, the Gambling Commission expects licensees to comply fully with the terms of their licence in relation to AML and CFT and to pay close attention to the various guidance documents it issues. Compliance and enforcement activity continue to reveal that operators’ AML policies, procedures and controls are not fit for purpose and, in many cases, customers are allowed to gamble using the proceeds of criminal activity. The Gambling Commission has warned the industry that “a failure to digest [its] guidance and implement the legislative requirements applicable to Great Britain... must change, for these are not just regulatory matters but breaches of UK law” and that “[t]hose failing to learn these lessons will face further draconian action”.
enforcement powers. Instead, and given that the LCCP has specific rules on advertising, any gambling advertising breaches by a licence holder may lead to enforcement action by the Gambling Commission. This includes seeking criminal prosecution, as breach of a licence condition is a criminal offence under Sec- “Advertising” is widely defined under Section 327 of the Gambling Act 2005 and generally encompasses any action that encourages one or more persons, either directly or through an agent, to engage in facili- ties for gambling. This covers most forms of advertis- ing, including online content and emails to consumers. 9.3 Key Legal, Regulatory and Licensing Provisions See 9.2 Definition of Advertising . Advertising must be socially responsible and comply with the LCCP – in particular, SRCP 5.1.6. The key LCCP advertising provisions are that: tion 33 of the Gambling Act 2005. 9.2 Definition of Advertising • all advertising of gambling products and services should be undertaken in a socially responsible manner; • operators should comply with the UK Code of Non-Broadcast Advertising, Sales Promotion and Direct Marketing (the “CAP Code”), the UK Code of Broadcast Advertising (the “BCAP Code”) and the Gambling Industry Code for Socially Responsible Advertising (the “Industry Code”); • adverts must not include a child or young person, and no one who is, or seems to be, under 25 may be featured participating in gambling; • operators must satisfy themselves that their adverts are not misleading; • operators must comply with any provisions of the CAP and BCAP Codes in relation to free bet and bonus offers, including by stating significant terms and directing customers to the full terms, which should be no further than one click away; • no adverts should appear on any web page that provides advice or information on responsible gambling; • operators must not place adverts on websites pro- viding unauthorised access to copyrighted content
9. Advertising 9.1 Regulatory/Supervisory Agency
The ASA regulates UK advertising and, therefore, gambling advertising. However, it does not carry any
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