National Risk Assessment of Money Laundering and Terrorist Financing 2025
HM Treasury and the Home Office jointly published the National Risk Assessment of Money Laundering and Terrorist Financing 2025 (“NRA 2025”) on 17 July 2025, with the Ministerial Foreword stating that since the NRA’s last publication in 2020,
“The threat from money laundering and terrorist financing continues to evolve, shaped by new technologies, geopolitical tensions, and the increasing sophistication of criminal and terrorist networks.”
In addition, the UK, with “one of the largest and most open economies, ranking 6th by GDP globally and 2nd in Europe” continues to be exposed to a high level of money laundering (“ML”) risk.
Purpose of the NRA
The NRA 2025 identifies itself as “a central part of the UK’s “risk-based approach” to countering ML and terrorist financing (“TF”). The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (the “MLRs”), stipulate that HM Treasury and Home Office must undertake an NRA and ensure it is used to consider the appropriate allocation and prioritisation of resources to counter ML and TF. Supervisors and regulated firms must conduct their own risk assessments which must take into account the NRA. Their risk assessments should be used to put in place effective controls, policies and procedures to mitigate the risks identified. The NRA provides for regulated sectors “essential insight into how their services may be exploited for illicit purposes, and guidance on how these threats can be identified and mitigated.”
Regulated sector – Casino (remote and non-remote)
Gambling operators holding a casino licence from the Gambling Commission are expressly included within the regulated sector by the MLRs. In the NRA 2025, the casino industry is highlighted as one of the sectors with the highest risks of exposure in relation to ML through cryptoassets. For further information on how cryptoassets is used as a ML typology, see pages 39 – 42.
Section 5 – Sector Specific Risks , sets out further information on the risks of casino as a regulated activity.

Importantly, the risk for ML has increased to “Medium”, with the following being the main drivers of increased risk:
- changes in customer, geographical and transaction risks, particularly the increase in funds moving through remote casinos;
- new ways to play casino games; and
- the updated assessment of money service business (MSB) activities offered by some casinos in the UK.
In relation to the casino sector, the NRA 2025 also notes:
Casino sector vulnerabilities: The use of peer-to-peer poker by remote casino platforms carries a higher ML and TF risk, owing to the growing use of methods to achieve anonymity (there is an increase in the reported use of false identities in an attempt to gain access to casinos). Other vulnerabilities include exposure to higher risk payment methods (including those linked to MSBs), and the use of white-label partnerships.,
Remote slot gaming: The combination of the increased scale and volume of slot gaming with the risks of non-face-to-face business relationships alongside noncompliance with customer due diligence (“CDD”) requirements by some casinos, also increases the risk of ML and TF. Owing to limited data, it is not yet possible to assess the likely impact of the UK government’s new slot stake limits (£5 limit for all adults from 9 April 2025, and £2 limit for adults aged 18 to 24 from 21 May 2025) in mitigating UK ML and TF risks.
Emerging risks: These include (i) increasingly sophisticated attempts to bypass CDD checks using false documentation and by deploying artificial intelligence – albeit this risk is not limited to casinos and (ii) crash games, which pose an opportunity to launder criminal funds through regulated casino operators, as “criminals could conceal the high risk behaviour of cashing out quickly with limited gameplay within the context of the crash game (where these behaviours are inherently more common)”.
Unregulated sectors
In terms of sectors unregulated by the MLRs that offer gambling legally, remote bingo, remote betting, and non-remote off-course betting are also considered to pose a high risk of ML and TF. In addition, for remote gambling activities, the use of e-wallets can result in the co-mingling of funds from regulated and unregulated sectors which could make investigation by law enforcement agencies more difficult. In respect of off-course retail betting, there are risks associated with the ability to deposit cash which can then be used for remote betting accounts, which makes transaction chains complex. In terms of wider betting-related criminality, there are concerns regarding illegal betting groups manipulating or creating false markets and “the widening availability of betting markets” poses threats such as the emergence of political and novel betting markets.
Illegal casinos which fall outside of regulation by the MLRs or supervision by the Gambling Commission have also been considered, with the use of cryptoassets in illegal casinos also increasing. The Gambling Commission took joint action with the police and search providers in 2024/2025 to address the respective risk from both remote and non-remote illegal casinos.
Next steps
Licensees should take the increased ML risk rating for casinos in the NRA 2025 into account when conducting their own ML and TF risk assessments. Following publication of the NRA 2025, the Gambling Commission has confirmed that it will review and update its risk assessment of the British gambling industry.
If you have any questions regarding the NRA 2025 or your own risk assessment, please do not hesitate to get in touch.