Global menu

Our global pages


Regulator shows their hand: Gambling Commission publishes AML Guidance and Assessment

  • United Kingdom
  • Fraud and financial crime
  • Litigation and dispute management


The Gambling Commission (the “Commission”), the UK's gambling regulator, has recently published two documents on money laundering and terrorist financing in the sector.

In March the Commission confirmed that the UK government had formally approved its latest guidance for remote and non-remote casinos in the UK (the “AML Guidance”). This approved status means that the AML Guidance must now be taken into account in prosecutions for failure to report a suspicion of money laundering under the Proceeds of Crime Act 2002, failure to report a suspicion of terrorist financing under the Terrorism Act 2000, or failure to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the “MLR 2017”).

The fourth edition of the AML Guidance explains the relevant legal framework for the sector, sets out good industry practice under a proportionate risk-based approach, and gives guidance for operators when developing and implementing their required policies, procedures and controls.

The AML Guidance provides considerable detail on matters including customer due diligence, the responsibility of senior managers, record keeping and suspicious activity reporting.

In addition, the Commission’s updated sectoral risk assessment (the “Assessment”) was published on 26 March 2018. Under Regulation 18(2) of the MLR 2017, casinos will need to take into account the Assessment when completing their own AML risk assessments.

The Assessment sets out the key risks in each of the gambling sectors which the Commission covers, including betting, bingo, gaming machines, casinos and lotteries. The higher risk sectors are identified in the Assessment as betting, casinos and forms of remote gambling.

The Commission make clear that the industry is not immune to money laundering and faces varied, complex and evolving risks to which operators should be alert. If you require any further information on how to identify and mitigate risks in this area, do get in contact with one of our team.