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04Aug

Gambling Commission publishes 2026 Money Laundering Risk Assessment

4th August 2026 James Frudd Anti-Money Laundering, Gambling Commission 225

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.

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07Jul

DCMS confirms increase to Gambling Commission fees from 1 October 2026

7th July 2026 Ruby Duncalf White Paper 282

A review of Gambling Commission fees was originally proposed in the government’s White Paper, High stakes: gambling reform for the digital age in April 2023. Over three years on from the publication of the government’s White Paper, the Department for Culture, Media and Sport (“DCMS”) has announced that the Gambling Commission’s fees shall increase from 1 October 2026. DCMS originally consulted on an increase to Gambling Commission operating licence fees between 27 January 2026 to 30 March 2026, tabling three main proposals in respect of the structuring of the increase in licence fees (“Consultation”).

Since the Gambling Commission’s fees were last reviewed in 2021, the Gambling Commission has increased its investment in areas including disrupting the illegal gambling market, data capabilities, enhancing core operational functions and implementing reforms proposed in the White Paper. Alongside additional pressures, such as inflation, DCMS recognised a need for review of the current fee structure that has been in place since 2017.

What are the changes to Gambling Commission fees?

In its consultation response published on 30 June 2026 (“Consultation Response”), DCMS confirmed that, based on the 47 consultation responses received, it would be diverging from most of its original proposals set out in the Consultation. The government will effect the following changes to Gambling Commission fees through secondary legislation:

  1. Annual fees and application fees will increase by a headline 25%, with the exception of:
  • Society lotteries, for which licence fees will be frozen.
  • General betting (limited) operating licences, where the basis on which fees are set will be adjusted to a market share-based approach based on gross gambling yield (GGY), rather than the number of days of operation.

For full details of the changes to annual fees by licence type, please see Annex One of the Consultation Response or for details of changes to application fees, please see Annex Two. 

  1. New fee categories will be introduced for most licences.
  2. An increase of 25% for personal licences, supplementary operating licences and single machine permits. Personal Management Licence application fees will therefore increase from £370 to £463. For full details, please see Annex Three of the Consultation Response.
  3. Fees for variations and changes of corporate control will also increase by 25%. For full details, please see Annex Three of the Consultation Response.
  4. First annual fees will continue to be charged at 75% of the annual fees. For full details, please see Annex Three of the Consultation Response.

For reference, the Consultation originally proposed three different options with increases to licence fees of (a) 30%, (b) 20%, or (c) 20% plus 10% ringfenced for illegal markets, revenue protection and related activities.

Following the Consultation, the Gambling Commission’s view is the DCMS’s findings now provide certainty on the Gambling Commission’s future income for the coming years. It should be noted that the changes to fees are subject to the passage of secondary legislation, which is planned to take effect on 1 October 2026.

What can operators expect?

The Gambling Commission has confirmed that, over the coming weeks, it will be making contact with operators about further details on how the increase in Gambling Commission fees will affect them and will provide information about alignment to any new fee category. The Gambling Commission will use licensee’s submitted regulatory returns data for 2025 to 2026 to determine its new fee category.

Next steps

Please get in touch with us if you have any questions on the increase to Gambling Commission’s fees or would like to discuss regulatory returns reporting or fee category tracking to ensure you are in the correct fee category.

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02Jul

Important updates to the Money Laundering Regulations 2017 for casino licensees

2nd July 2026 Ruby Duncalf Anti-Money Laundering 304

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.

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21May

IAGA Gaming Summit 2026 – join us for the responsible gambling panel moderated by David Whyte

21st May 2026 Harris Hagan Event, Harris Hagan, Responsible Gambling, Uncategorised 382

The 43rd annual International Association of Gaming Advisors (IAGA) Summit will be held at the Ritz-Carlton in Sarasota, Florida from 2 – 4 June 2026.

As part of the 2026 Summit Agenda, Partner, David Whyte, who also sits on IAGA’S EMEA Engagement & Steering Committee will moderate the panel Innovations and Global Perspectives in Responsible Gambling on Thursday 4 June 2026. The session will explore:

  • The latest trends in responsible gambling programs worldwide, featuring insights from the UK’s advanced initiatives and the Better Gambling Forum’s work.
  • How the industry is addressing the negative community impacts of betting, including player health and youth protections, and compare international approaches to self-exclusion.
  • The funding models for research, prevention, and treatment and examining models across jurisdictions that do or do not work. 

The session’s panellists are:

Stephen Martino, Chief Compliance Officer

Sarah McCarthy, CEO, Responsible Gambling Council 

Jamie McKelvey, Deputy Attorney General and Responsible Gaming Coordinator, New Jersey Division of Gaming Enforcement

Kane Purdy, Managing Director, Gamesys Operations Limited, and Chair, GamProtect, UK

Sarah Taylor, Executive Director, Hoosier Lottery

Date: Thursday 4 June 2026

Time: 1-2pm

Location: Ritz-Carlton, Sarasota

Register for the 2026 Gaming Summit. All Harris Hagan Partners will be in attendance – if you would like to arrange a meeting, please do not hesitate to get in touch.

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14Apr

Casino sector AML guidance updates

14th April 2026 Ruby Duncalf Anti-Money Laundering, Harris Hagan, Responsible Gambling, Uncategorised 365

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.

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19Jan

Reminder: Socially responsible incentives come into effect on 19 January 2026 

19th January 2026 Ruby Duncalf Harris Hagan, Responsible Gambling, Uncategorised 400

Licensees are reminded that the changes to Social Responsibility Code Provision (“SRCP”) 5.1.1  came into effect today, 19 January 2026. The changes apply to all licences (including ancillary licences), except gaming machine technical and software licences.

Summary of changes

Further to the Gambling Commission’s Autumn 2023 consultation response, the new promotional rules, as outlined in our previous blog, resulted in three main changes that came into effect today:

  1. Mixed product promotion ban.
  2. Bonus wagering requirements limited to 10.
  3. Rewording SRCP 5.1.1 Rewards and Bonuses section of the Licence Conditions and Codes of Practice to read:

Social Responsibility Code 5.1.1 Rewards and Bonuses

 1.   The following applies where a licensee makes available to any customer, or potential customer, an incentive or reward scheme or other arrangement under which a customer may receive money, goods, services or any other advantage (including the discharge in whole or in part of any liability of his) (‘the benefit’).

 2.  Licensees must:

a.   Set out terms and conditions, in relation to an incentive, which are clear, transparent, and fair and readily accessible to any customer or potential customer to whom it was offered.

3.  Licensees must not:

a.   Apply wagering requirements, which requires a customer to play through bonus funds, over a maximum of 10 times. A wagering requirement is where a customer is required to make wagers totalling a particular value for funds to become withdrawable.

b.   Include more than one type of gambling product (betting, casino, bingo, and lottery) within an incentive.

c.   Alter or increase the receipt or the value, or amount of the incentive if the qualifying activity or spend is reached within a shorter time than the whole period over which the benefit is offered.

d.   Construct incentives where, if the benefit comprises of free or subsidised travel or accommodation which encourages the customer’s attendance at a particular licensed premises, it is offered on terms that directly relate to the level of the customer’s prospective gambling.

Guidance on compliant product promotions

The Gambling Commission’s blog ‘Socially responsible incentives: what operators need to know’ published on 12 December 2025 includes helpful guidance on acceptable forms of product promotions following the Gambling Commission’s ban on mixed product promotions that came into force today. In summary, the following are examples of compliant and non-compliant product promotions:

Examples of compliant promotions

    • Promotions that do not mix product types between the initial customer activity and the prize. For example, ‘Bet £5 and get a £10 free bet’.
    • Promotions where the initial customer activity and the prize are both within the same product category. For example, ‘Spend £5 on casino products and get 20 free spins’.
    • Promotions that are construed in a manner that allows the customer to have full freedom of choice in which product category to use credits or bonus money, for example, ‘Bet £5 to get £10 credit or bonus to be used on all products available’.
    • Promotions that allow the customer the freedom to choose which product category they chose to play and the prize or reward is also not limited to product category. For example, ‘Spend £10 on any licensed product of your choice and get £10 credit or bonus to spend on your choice’, or ‘Deposit £5 (not linked to participation of a product category) and get £5 credit or bonus of any licensed product’.

Examples of non-compliant promotions

    • Promotions that mix product types. For example, ‘Bet £5 to get 20 free spins’. This offer invites the customer to participate in one type of gambling activity, to get a prize from a different product category.
    • Promotions that offer a prizes in respect of different products. For example, ‘Bet £5 and get a £5 free bet and 20 free spins’.
    • Promotions that provide the customer with the choice of initial qualifying activity but specify the product category to which the prize is applicable. For example, ‘Spend £10 on any licensed product of your choice and get £5 free bet’.

Next steps

Licensees are encouraged to review the changes to SRCP 5.1.1 to ensure that all necessary changes are made from today, 19 January 2026. Please get in touch with us if you have any questions about the socially responsible incentives.  

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22Dec

Department for Culture, Media and Sport publish voluntary Code of Good Practice for prize draw operators

22nd December 2025 Ruby Duncalf Harris Hagan, Responsible Gambling, Uncategorised 330

On 21 November 2025, the Department of Media, Culture and Sport (“DCMS”) published the Voluntary Code of Good Practice for Prize Draw Operators (the “Code”) in Great Britain.  DCMS estimates the annual market value of the prize draw sector to be £1.3 billion with 7.4 million adult participants annually across approximately 400 operators. DCMS recognises that whilst the operation of prize draws does not require a licence under the Gambling Act 2005, research has shown how prize draws sit adjacent to the gambling industry, presenting concerns in light of gambling-related harms. The Code, agreed by the Government and a significant number of prize draw operators, aims to strengthen player protections and ensure that individuals who participate in prize draws do so more safely.

Purpose and scope of the Code

The Code applies to prize draws in Great Britain where:

a)         the outcome (and therefore allocation of prizes) is determined by chance; and

b)         there is both a paid entry route and a free entry route.

The Code outlines key measures that prize draw operators are expected to implement to strengthen player protections and ensure that those who participate in these draws do so more safely. The Code is voluntary, applies only to free-entry draw elements of a business, and does not replace existing regulation and requirements for prize draw operators. Any failure to abide by the Code will not itself constitute a breach of an operator’s legal responsibilities.

Implementation timeline

At the time of writing, the Code has been signed by 141 signatories who have committed to implement the Code in full within 6 months of its publication and not later than 20 May 2026 (“Implementation Date”). Operators becoming a signatory of the Code after the Implementation Date must ensure their full compliance immediately. In the absence of an established industry trade body, signatories are expected to share practices on how to implement measures and work with operators who are not yet signatories to the Code to adopt these measures and subsequently join the Code.

Oversight and compliance

DCMS will have oversight of the Code, reserving the right to delegate oversight to an industry trade body as necessary. DCMS will periodically review the Code’s effectiveness, noting that should the Code not be suitably implemented or complied with, DCMS reserve the right, following consultation, to introduce changes where necessary.

All signatories of the Code have agreed to act in good faith. If concerns arise about non-compliance, these should first be raised with the relevant operator or by contacting DCMS at [email protected].  

The Code

The Code is divided into three core areas: Player Protections, Transparency, and Accountability, each summarised in turn below.

  1. Player protections

a)   Prize draws should only be made available for players aged 18 or over with a reasonable age verification process in place. Advertising should not be targeted at under 18s.
b)   Credit card payments in excess of £250 per month per player should not be accepted.
c)   Suitable proportionate maximum monthly total spends should be set for players or players should be permitted to set their own, including the option to set a limit at £0.
d)   The option to suspend or permanently close an account should be provided to players.
e)   Reasonable efforts should be made to have effective systems and processes in place to monitor player activity to identify harm or potential harm.
f)   Where operators are able to identify any indicators of harm, they should take a tailored and proportionate approach to intervention that mitigates harm and encourages      responsible play.
g)   Operators should signpost players to available support for those experiencing harm.
h)   An appropriate time period should lapse between a prize draw opening and concluding.
i)   Operators should ensure that all marketing and advertising of their prize draws is in line with the CAP and BCAP code, and should be undertaken in a socially responsible manner.

This section of the Code also covers complaints processes, operators’ conduct during a player’s suspension, measures in relation to instant win games, and further requirements regarding marketing and advertising.

  1. Transparency

a)   Operators should provide a clear summary of how each prize draw works, including the statement that prizes are to be awarded by chance.
b)   Promoters of prize draws should ensure that prizes are awarded fairly in accordance with the rules and terms displayed to players, and this should be by (or under the supervision of) an independent person, unless the winners are selected by a computer process that produces verifiably random and auditable results, or by a certified physical drawing machine.
c)   Where possible, prior to entering a draw, operators should provide players with clear and easily accessible information regarding the likelihood of winning a prize and how prizes will be allocated.
d)   Operators should clearly and prominently provide players with details of any “free entry” options for the prize draw before the point of purchase, and in line with the requirements of the Gambling Act 2005.
e)   Operators should promptly provide the winning player with the advertised prize for a draw or a reasonable cash alternative.

This section of the Code also covers charitable contributions and further details regarding free entry options.

  1. Accountability

a)   Operators should have processes in place to monitor and regularly review their own compliance with the Code and, where inadequacies are identified, take swift actions to ensure compliance with the Code.
b)   Operators should take reasonable steps to ensure that all relevant Code requirements are also followed by any third parties that support their prize draw operations, such as affiliate marketers or draw management partners. Where third parties are not compliant with the Code, terminating relationships should be considered.
c)   Operators should engage with other operators to share best practice in relation to player protections, transparency and accountability.
d)   Operators should publish all of the measures they have in place relating to player protections, transparency and accountability, and ensure their adherence with the Code is transparently displayed on their websites.
e)   Operators are encouraged to work with DCMS to ensure the Code remains fit for purpose and share any learnings or challenges.

The full Code and requirements can be found here.

Next steps

Please get in touch with us if you have any questions about the implementation or compliance with the Code.

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24Oct

Reminder: Updates to the RTS and transparency of protection of customer funds come into effect on 31 October 2025

24th October 2025 Ruby Duncalf Uncategorised 192

Licensees are reminded that updates to the remote gambling and software technical standards (“RTS”), along with new requirements regarding the transparency of protection of customer funds, come into effect on 31 October 2025. We previously reported on the upcoming changes here, and this post serves as a timely reminder to ensure all licensees are fully prepared for the upcoming changes. Licensees should ensure they are compliant with the requirements before 31 October 2025.

Summary of the RTS updates

Following the Gambling Commission’s response to its Autumn 2023 consultation, amendments to RTS 12 – Financial limits are scheduled to come into effect at the end of the month. These changes will apply across all gambling products, with the exception of subscription lotteries. For ease of reference, we have set out below the RTS 12 in effect from 31 October 2025. Licensees should familiarise themselves with the updated RTS to ensure they are compliant.

RTS requirement 12A

The gambling system must provide easily accessible facilities for customers to set their own financial limits at any time from the point of registration. 

Customers must be prompted to set a limit as part of the registration process or at the point at which the customer makes the first deposit or payment. The limit must be implemented as soon as practicable after the customer’s request. The customer must be informed when the limit will come into force. 

RTS implementation guidance 12A:

  1. Limits could be in the form of:
    1. deposit limits: where the amount a customer deposits into their account is limited over a particular duration.
    2. spend limits: where the amount a customer spends on gambling (or specific gambling products) is restricted for a given period – this type of limit may be appropriate where the customer does not hold a deposit account with the operator.
    3. loss limits: where the amount lost (that is, winnings subtracted from the amount spent) is restricted (for instance when a customer makes a £10 bet and wins £8, the loss is £2).
  2. The period/duration of the limits on offer should include:
    1. 24 hours;
    2. 7 days; and
    3. one month
  3. where a customer sets simultaneous time frames, for example a daily deposit limit and a weekly limit, the lowest limit should always apply. Therefore, if a daily deposit limit of £10 and a weekly limit of £100 are both set then the maximum the system should allow to be deposited is £10 per day and £70 per week.

RTS requirement 12B

Customers must be presented with a ‘free text’ box to set a limit, or the equivalent in the case of telephone gambling. 

As a minimum, limits must be applied at the account level. 

RTS implementation guidance 12B:

  1. In addition to account-level limits, limits could be implemented across individual products or channels. Where gambling licensees offer the facility to set limits for individual products or channels it should be made clear to customers using the facility whether those limits apply at the account or product/channel level. For example, where a limit has been set for a specific game, a customer should not be misled into assuming that the limit automatically applies to other products.
  2. Where a customer sets simultaneous time frames, gambling licensees should provide clear information on how the interaction between those limits works.
  3. Operators could provide links to tools or resources to inform budgeting and aid customers in determining appropriate limits for their personal circumstances.
  4. In order to mitigate against user error, the gambling system could permit specific monetary increments for limits, such as whole pounds.

RTS requirement 12C

Financial limit facilities must be provided via a direct link on the homepage and be clearly visible and accessible. 

Financial limit facilities must be clearly visible and accessible on deposit pages/screens or via a direct link on these pages or screens. 

The gambling system must minimise the number of clicks or pages customers make in order to access financial limit facilities.

RTS implementation guidance 12C: Links to limit-setting facilities from communications such as emails or notifications should link directly to the facilities and not via a home page or other intermediate page(s), unless required by account log in security settings.

RTS requirement 12D

Customer-led limits must only be increased at the customer’s request, only after a cooling-off period of at least 24 hours has elapsed and only once the customer has taken positive action at the end of the cooling off period to confirm their request. 

Unless systems/technical failures prevent it, customer-led reductions to limits must be implemented immediately.  

The gambling system must provide a prompt to customers to review their own account and transaction information, as is currently made available under RTS 1 – Customer account information. This must be provided at a minimum of six-month intervals for accounts with activity within a rolling 12-month period. Customers must be provided with facilities to set more frequent reminders to receive this statement and review their limits. 

RTS implementation guidance 12D:

  1. In the event of systems or technical failure not facilitating an automated and/or immediate reduction in limits, the customer should be informed when the limit reduction will take effect.
  2. Operators should monitor engagement with and responses to alerts, in order to inform good design and best practice.

RTS requirement 12E

Financial limit-setting facilities must present setting a limit as the default choice. The gambling system must require an action by the customer in order to decline setting a limit. 

The gambling system must receive confirmation that the customer does not wish to set a limit before moving on to deposit/gamble. 

The gambling system must prompt existing customers without limits set to review this position as a minimum on an annual basis.

RTS implementation guidance 12E:

  1. Presentation of financial limits as the default option could take the form of pre-selected fields such as tick boxes, or through visual distinction.
  2. Action to decline setting a limit and receiving confirmation could take the form of a tick box, dismissing a message or other action by the customer.
  3. Customers who choose to opt out of setting a limit could be provided with information or links to tools and resources such as budgeting tools and information about safer gambling.

Please note that on 7 October 2025 the Gambling Commission published its response to its supplementary consultation on the definitions of different types of financial limits, which will result in further changes to RTS 12 which will take effect on 30 June 2026.

Summary of update to transparency of customer funds

On 31 October 2025, licence condition 4.2.1 shall be amended with a paragraph added at licence condition 4.2.1(3). Subsequent paragraphs will be renumbered accordingly. The amendment shall apply to all operating licences, with the exception of gaming machine technical standards, gambling software, host, ancillary remote bingo and ancillary remote casino licences.

Under the updated licence condition, licensees who have selected a ‘not protected’ rating (i.e. in the case of a gambling company becoming insolvent, any money in a customer’s account would be classed as part of the company’s assets), will be required to remind customers every six months that their funds are not protected in the event of insolvency. The reminder must refer to the value of funds held for the customer. The licensee must require the customer to acknowledge receipt of the information and must not permit the customer to utilise the funds for gambling until they have done so.

Next steps

Licensees are strongly encouraged to review the revised RTS and implementation guidance in full, and updated licence condition 4.2.1, to ensure all necessary changes are made ahead of the 31 October 2025 implementation date.

Please get in touch with us if you have any questions about the upcoming changes.

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10Oct

Gambling Commission publishes update on emerging money laundering and terrorist financing risks

10th October 2025 Ruby Duncalf Anti-Money Laundering 234

As part of the Gambling Commission’s ongoing efforts to combat financial crime in the UK gambling sector, its latest emerging risk update (October 2025) highlights the continued and evolving risks posed by pre-payment methods.

This serves as a critical reminder to operators to review their money laundering and terrorist financing (“MLTF”) risk assessments and related policies, procedures and controls.

Why this matters

Under licence condition 12.1.1(3) of the Gambling Commission’s Licence Conditions and Codes of Practice, operators are required to remain informed of emerging MLTF risks, ensuring that such policies, procedures and controls are updated as needed, implemented effectively, and remain effective, taking into account any guidelines published by the Gambling Commission from time to time.

The Gambling Commission’s October 2025 update reinforces earlier emerging risks bulletins published in April 2020 and February 2022 and the Gambling Commission’s 2023 MLTF Risk Assessment, which classified pre-paid payment methods as high risk.

Pre-paid payment methods: Key risk factors

The Gambling Commission considers pre-paid payment methods as high risk due to a variety of factors, including:

  • Merging of funds – the ability to pre-pay or pre-load using cash and, in some cases cryptoassets either directly or through third party websites.
  • Anonymity – the anonymous nature of some pre-paid payment methods and lack of traceability.
  • Credit card circumvention – the ability, in some cases, to pre-pay using credit cards.
  • Deposits – the open-loop nature of pre-paid methods often do not allow deposits back onto the original card or voucher.

What operators need to do

  1. Update your MLTF risk assessment

In accordance with licence condition 12.1.1, licensees must consider all payment methods in their MLTF risk assessment, including pre-paid cards and pre-paid vouchers. This October 2025 emerging risk bulletin notes that the Gambling Commission’s expectation is that pre-paid payment methods should be treated as high risk, in accordance with the Gambling Commission’s own risk assessment.

  1. Conduct appropriate customer profiling and due diligence checks 

The use of pre-paid payment methods must be factored into a customer’s risk profile, and the operator must conduct appropriate due diligence checks. Additional ‘know your customer’ (“KYC”) and source of funds/source of wealth checks are also expected to be conducted by the operator when a customer is identified as presenting a higher risk.

The Gambling Commission reminds operators that they are ultimately responsible for ensuring sufficient customer checks are conducted and that they must not rely on a third party payment processor to conduct such checks on their behalf, or rely on third parties to establish source of funds without scrutiny.

  1. Submit a key event notification (if appropriate)

Licence condition 15.2.1(8) requires operators to submit a key event to the Gambling Commission where there are any changes to the methods by which, and/or the payment processors through which, the licensee accepts payment from customers using their gambling facilities. The Gambling Commission expects such key event notifications to contain the following information as a minimum:

  • The type of payment method.
  • The provider.
  • How the payment method was assessed in the operator’s MLTF risk assessment.
  1. Do not accept payment by credit card

The Gambling Commission reminds licensees that under licence condition 6.1.2(1) they must not accept payment for gambling by credit card, including payments to the licensee made by credit card through a money service business or top up methods for pre-paid cards. Operators must ensure that where pre-paid methods are authorised, they are not used to circumvent this restriction.

  1. Review and update policies and procedures

Licence condition 12.1.1(2) requires that following completion of, and having regard to, the MLTF risk assessment, licensees must ensure that they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing. Licensees must therefore ensure that whenever they update their MLTF risk assessments, their anti-money laundering (“AML”) policies, procedures and controls are also reviewed and updated as needed. 

Next steps

Please get in touch with us if you have any questions or would like further advice on updating your AML policies and procedures, and  sign up to our blog to make sure you receive updates on any emerging MLTF risks.

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17Sep

White Paper Series: Payment of the first statutory levy now due

17th September 2025 Ruby Duncalf White Paper 253

On 1 September 2025, licensees should have received their first invoice in respect of the Government’s statutory levy. The Gambling Levy Regulations 2025 (“the Regulations”) took effect on 6 April 2025 and introduced a mandated levy on all operating licence holders in Great Britain to fund research, prevention and treatment of gambling harms, which replaces the previous system of RET payments, of which the amount contributed was voluntary.

The Gambling Commission has now provided its guidance on the calculation, collection and payment of the statutory gambling levy (the “Guidance”), which we outline below.

  1. How the statutory levy is calculated

The levy is charged at a set rate ranging from 0.1% to 1.1% of the “leviable amount” (defined in regulations 2(3)-(5) of the Regulations) depending on the licensed activity.

For the majority of operators, the levy is calculated based only on gaming facilities provided to customers in Great Britain (“GB”). For licensees that hold a gambling software licence or are required to hold a licence because they site key remote equipment in GB, the levy is calculated on income deriving from those activities, whether in GB or abroad.

The calculation for the amount owed under the statutory levy is based on the data that licensees provide to the Gambling Commission via their quarterly regulatory returns. The Guidance reminds licensees of their obligation to provide ‘true and correct’ data in their returns, and that any incorrect data submitted would impact the calculation of the amount owed under the levy, and risks licensee non-compliance with the law.

  1. Timing of the statutory levy

The calculation for the first statutory levy period for all licences (except for lottery operating (society) licences) is based on regulatory returns data covering the period July 2024 to March 2025, multiplied by one and one-third. For society lottery licensees, it is based on data for the period 1 April 2024 and 31 March 2025.

Going forward, for all licensees, the statutory levy will be calculated on regulatory returns data from April through to the following March. Invoices will be issued annually on 1 September and will be based on the licensee’s activity from the previous financial year.

  1. Payment of statutory Levy

The first invoices were issued to licensees on 1 September 2025 with full payment required before 1 October 2025. Invoices are available in the invoices tab on licensees’ eServices accounts, and payment can be made by GovPay or bank transfer.

Statutory levy payments must be paid in full (they cannot be made in instalments) only after the invoice has been issued, and before 1 October in the relevant year. Payments must be made to the correct bank account, quoting the invoice number in full, and must not be combined with any other payments to the Gambling Commission. If the levy payment does not meet these requirements, there is a risk that it may be returned and the operating licence could be at risk of revocation.

  1. Invoices relating to GB and non-GB activity

For the first statutory levy period, each licensee will receive one combined invoice for all GB activity and a second invoice for non-GB activity, if appropriate. Operators must pay the full amount of the GB activity invoice before 1 October 2025.

In relation to non-GB activity, the Gambling Commission recognises that some operators may have submitted returns that that either do not fully account for leviable foreign income, or include non-leviable foreign income. If a licensee believes that the Gambling Commission’s non-GB invoice includes non-leviable activity from foreign customers, it is the operator’s responsibility to notify the Commission promptly, and in any case before 1 October 2025, and provide full reasons at to why they believe particular sums are not due. The Gambling Commission will suspend enforcement of that element of the levy until the query is solved.

  1. Incorrect invoices

It is the operator’s responsibility to notify the Gambling Commission if its invoices do not include any sums that ought to be brought into account, and to pay the full sums due, including any shortfall. If it fails to do so, the Gambling Commission may take enforcement measures, including revocation of the licence pursuant to section 119 of the Gambling Act 2005.

Operators should notify the Gambling Commission of any such errors by email at [email protected].

  1. Consequences of not paying the statutory levy

Payment of the statutory levy is a licence requirement, and therefore non-payment, or late payment of the levy, by the licensee could result in revocation of the operating licence, unless the Gambling Commission is satisfied that the late or non-payment is due to an administrative error.

Next steps

Licensees can prepare for the statutory levy payment by ensuring:

  • regulatory returns data is submitted correctly and on time;
  • they have access to their organisation’s eServices account;
  • the Gambling Commission holds the correct contact details (i.e. email address) for their organisation; and
  • payment is only made once an invoice has been received.

Please get in touch with us if you have any questions about the Regulations or payment of the statutory levy.

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