On 30 June 2026, a series of changes to The Money Laundering Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (“MLRs”) came into effect. The MLRs apply to licensees holding remote and non-remote casino operating licences, although, all operators should consider the recent changes against their money laundering and terrorist financing risk assessments (“MLRA”).

What are the changes to the MLRs and what does this mean to casino licensees?

Following parliamentary debate, and approval, on 9 June 2026, the following changes to the MRLs came into effect on 30 June 2026.

High risk jurisdictions

Casino licensees are required, pursuant to Regulation 33 of the MLRs to apply enhanced customer due diligence (“ECDD”) where the relevant transactions or customer relationships involve a person established in any high-risk third country, defined as a country named on the list of High-Risk Jurisdictions on the Financial Action Taskforce’s (FATF) ‘Call for Action’ country list only. Prior to 30 June 2026, the definition of a high-risk third country also included referenced to FATF’s ‘Increased Monitoring’ list.

In its bulletin on the changes to the MLRs, the Gambling Commission noted that the refined definition of high-risk third country enables casinos to focus on money laundering and/or terrorist financing threats faced specifically by the UK. The Gambling Commission reminds casino licensees that they are continued to require to apply ECDD measures based on geographic risk in accordance with Regulation 33(6)(c) of the MLRs, including taking into account FATF lists and other FATF assessments.

Unusually complex and unusually large transactions

Regulation 33(1)(f) of the MLRs now requires casino licensees to apply ECDD measures and enhanced ongoing monitoring in any case where a transaction is “unusually complex or unusually large”. This replaces the previous wording where ECDD was required in cases where a transaction was complex or unusually large.

Currency thresholds

The MLRs have now been updated so that any reference to Euros is now to Sterling. This is particularly relevant to Casino licensees in relation to Regulation 27(5) of the MLRs, as the threshold for customer due diligence measures in relation to specific transactions (set out at Regulation 27(6) of the MLRs) is now £2000.

Clarification on business relationships

The Gambling Commission’s bulletin on the changes to the MLRs sets out that the Gambling Commission’s The prevention of money laundering and combating the financing of terrorism guidance (“Casino Guidance”) will soon be updated to provide further details on the establishment of business relationships.

What should casino licensees do?

The Gambling Commission expects casino licensees to update their MLRA as a result of the changes to MLRs, which in turn, will prompt a review of their policies, procedures and controls.

The Gambling Commission has also announced changes to the Casino Guidance in due course. We remind licensees that licence condition 12.1.1 requires licensees to update their MLRA, as necessary, in light of any changes of circumstances and ensure policies, procedures and controls are implemented effectively, taking into account any applicable learning or guidelines published by the Gambling Commission from time to time. In any case, licensees must update their MLRA at least annually.

Next steps

Please get in touch with us if you have any questions about updating your MLRA or policies, procedures and controls.