The Gambling Commission has recently issued two notices relevant to both remote and non-remote casino operating licence holders, reflecting its ongoing expectations in relation to anti-money laundering (“AML”) and compliance. The updates relate to (1) the new digital identity guidance published by HM Treasury and (2) guidance for casinos offering Money Service Business (“MSB”) services.

1. New digital identity guidance

On 26 February 2026, HM Treasury published its new digital identity guidance setting out how entities regulated under the Money Laundering Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLRs”), including casinos, can use digital identity services for customer due diligence checks (“Digital Identity Guidance”).

The Digital Identity Guidance confirms that digital identity services certified against the UK digital verification services trust framework and listed on the Digital identity and attribute services register can be used by regulated entities as part of their customer due diligence processes, specifically to satisfy their obligations under Regulation 28 of the MLRs. Entities should also ensure that any digital identity services used comply with the record-retention requirements in Regulation 40 of the MLRs. Digital identity services which are not certified and therefore not on the Digital identity and attribute services register cannot reliably be deemed suitable for identity verification in compliance with the MLRs.

The Digital Identity Guidance states that regulated entities should continue to make their own assessment of a customer’s risk and apply enhanced due diligence measures where appropriate, noting that digital verification services are unable to fulfil all aspects of customer due diligence such as assessing and maintaining information on a customer and the purpose and intended nature of the business relationship or occasional transaction. Regulated entities should be mindful that they remain liable for any failures to apply appropriate due diligence measure when using digital identity services.

     2. Guidance for casinos offering MSB activities and update notice

Casinos that provide services to customers such as acting as a cheque casher or currency exchange, accepting winners’ cheques and foreign currency or transmitting money are considered to be providing MSB activities under the MLRs. Whilst ordinarily MSBs are regulated by HM Revenue & Customs (“HMRC”), pursuant to Regulation 7(2) of the MLRs, the Gambling Commission and HMRC have agreed that the Gambling Commission will act as the supervisory body for casinos carrying out incidental MSB activities.

All casinos offering MSB services are required to register with HMRC. On 8 January 2026, the Gambling Commission entered into an agreement with HMRC that the Gambling Commission will provide the necessary registration details of those operators providing MSB services directly to HMRC to facilitate their registration. The Gambling Commission issued a further notice on 26  March 2026 requiring casinos offering MSB activities to notify the Gambling Commission within 10 days from the date that they started or stopped providing MSB services, alongside the following information:

• Full name of casino
• Licence number
• Date the MSB service started or stopped
• Type of MSB service

This information is to be emailed to the Gambling Commission at [email protected].

Casinos providing certain payment services, such as money remittance or any other payment service, as defined under Schedule 1 of The Payment Services Regulations 2017 (The PSR 2017)  must also be authorised or registered with the Financial Conduct Authority. In this instance, licensees holding a casino operating licence will also need to inform the Gambling Commission if they conduct any MSB activity covered under The PSR 2017.

Keeping up-to-date with AML guidance

It is no industry secret that the casino sector, in particular the non-remote casino sector, has been the subject of Gambling Commission focus over the last few months. With that in mind, operators should ensure that they stay up to date with the Gambling Commission’s latest notices and updates.

Please get in touch with us if you have any questions about the use of digital identity services, MSB activities in casinos or any other AML queries in relation to the remote or non-remote casino sector.