On 30 July 2026, the Gambling Commission published its Risk Assessment of Money Laundering and Terrorist Financing in the British Gambling Industry 2026 (“Risk Assessment”).

The Risk Assessment is an update to the Gambling Commission’s 2023 publication and takes account of, among other factors, HM Treasury and the Home Office’s National Risk Assessment of Money Laundering and Terrorist Financing 2025.

The Risk Assessment informs operators of the current risks in the British gambling industry and is an important resource for licensed operators when preparing their own money laundering, terrorist financing, and proliferation financing risk assessments.

The updated Risk Assessment also meets the Gambling Commission’s obligation under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLRs”) to identify and assess the risks of money laundering and terrorist financing in the casino sector.

What All Gambling Operators Need to Do

All licensees must assess the risks of their business being used for money laundering, terrorist financing, and proliferation financing under licence condition 12.1.1. Licensees under this licence condition must also take account of any relevant learning or guidance published by the Gambling Commission, including the updated Risk Assessment, and are therefore expected to consider the sections of the Risk Assessment that are relevant to their business.

Licensees should:

• consider how the risks identified may apply to their business;
• update their own risk assessments where appropriate; and
• use the risk ratings to help assess the level of risk to their business.

Where a licensee updates its own risk assessment, it must also review and, where applicable, update its policies, procedures and controls, including where risk ratings have changed.

Additional Requirements for Casino Operators

Casino licence holders have an obligation under the MLRs to take account of the Risk Assessment when preparing their own risk assessments.

Casino licensees must:

• consider how the risks identified in the Risk Assessment apply to their business;
• update their risk assessment accordingly; and
• keep an up-to-date record of the steps taken to identify and assess money laundering, terrorist financing, and proliferation financing risks.

Casino operators must use their risk assessments to inform their anti-money laundering and counter-terrorist financing policies, procedures and controls.

Gambling Commission Expectations

The Gambling Commission states that, in its role as supervisory authority, it has a duty to review casino risk assessments on a risk-based approach.

The Gambling Commission recognises that updates to risk assessments, policies, procedures and controls may require internal review and approval. However, it expects updates to be made in a timely manner and for casino operators to be able to demonstrate the steps taken to implement them.

Please get in touch with us if you have any questions about the Gambling Commission’s updated Risk Assessment of Money Laundering and Terrorist Financing 2026.