UK Trends and Developments Contributed by: Bahar Alaeddini, David Whyte and Jessica Wilson, Harris Hagan
highlighting that it is a criminal offence to provide facilities for gambling in Great Britain without an operating licence. It is highly likely that the Gambling Commission will continue to focus on this area in 2026 and that it will seek to set more defined expectations of licensees. AML AML has always been a key aspect of the regulatory landscape in Great Britain, given that the first licens- ing objective set out in the Gambling Act 2005 is to prevent gambling from being a source of crime or disorder, being associated with crime or disorder, or being used to support crime. However, there has been an increased focus on this area during the past 12 months, as technological developments and industry trends introduce new and evolving risks. Under Licence Condition 12.1.1 of the Gambling Com- mission’s Licence Conditions and Codes of Practice (LCCP), licensees are required to conduct an assess- ment of the risks of their business being used for money laundering and terrorist financing, taking into account applicable learning or guidelines published by the Gambling Commission. The Gambling Com- mission has published three “emerging risk” updates within 18 months, identifying new risks to the gam- bling industry that licensees must consider as part of their AML/CFT risk assessments. The risks identified include the following. • Use of AI to bypass customer due diligence – the Gambling Commission has become aware of an increase in attempts to bypass customer due diligence checks by using false documentation, deepfake videos and face swaps generated by AI. • Increased interest in crash games in the licensed casino sector – the fast-paced and highly vola- tile nature of crash games can allow criminals to hide behind the high-risk behaviour of cashing out quickly with limited game play, meaning that trans- actional monitoring controls may be less effective in detecting suspicious activity. • Licensed casino games on unlicensed websites – casino games developed by licensed software sup- pliers are being made available to the British mar- ket through unlicensed websites, putting licensed
operators at risk of accepting funds derived from criminal activity. Further, in July 2025, HM Treasury published an updated National Risk Assessment (NRA) of Money Laundering and Terrorist Financing – stating in the Ministerial Foreword that, since the publication of the previous NRA in 2020, “the threat from money launder- ing and terrorist financing continues to evolve, shaped by new technologies, geopolitical tensions, and the increasing sophistication of criminal and terrorist net- works”. Importantly, the NRA increased the money laundering risk for casinos from “low” to “medium”, with the main drivers of increased risk being: • changes in customer, geographical and transac- tion risks, particularly the increase in funds moving through remote casinos; • new ways to play casino games; and • an updated assessment of money service business activities offered by some casinos in Great Britain. The gambling industry is reacting to societal change and, with the ever-increasing use of AI, it is probable that new money laundering and terrorist financing risks to the gambling industry will be identified in the The Gambling Commission has continued to exercise its enforcement powers against licensees. An over- all raising of standards across the industry means that, generally, failings that have been identified are less severe; this has been reflected in the sanctions imposed. However, the pace of enforcement action has not slowed and recent enforcement activity (including two operating licence suspensions) might be indicative of a shift in approach. Common enforce- ment themes include: • non-adherence to enhanced customer interaction obligations; • inadequate consideration of money laundering and coming year. Enforcement
terrorist financing risks; • repeat offenders; and • unlicensed suppliers and/or operators.
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