The UK Gambling Commission has alerted operators to a range of emerging money laundering and terrorist financing risks, including crypto-assets and artificial intelligence (AI).
The Gambling Commission provided the update in its emerging risks bulletin published on April 8. There is also a licensing condition that requires licensees to consider the emerging risks information published by the commission.
A spokesperson for the Gambling Commission said: “The emerging risks bulletin is a trigger for operators to review their money laundering and terrorist financing risk assessments and related policies, procedures and controls to ensure that they remain appropriate and effective in the light of the risks information published.”
The commission told Vixio GamblingCompliance that it does not specify a deadline for this review but "does expect licensees to complete their review at pace, and this will be included in future compliance activity".
White-label partnerships, crash games and licensed software providers’ games being available on websites not licensed by the Gambling Commission are some of the other emerging risks flagged in the notice.
In recent months, there have been calls for the Gambling Commission to address crypto-assets, something the regulator said it is aware of.
However, the Gambling Commission takes the view of HM Treasury, which sees crypto-assets as a high-risk payment option. It also highlighted the significant theft of crypto-assets from the ByBit exchange in February 2025, which used complex money laundering schemes and, in the past, included remote gambling operators.
Another key emerging technology addressed by the emerging risks update is AI.
The regulator warns that AI is being used to bypass customer due diligence at increasing scale and sophistication, generating false documentation, deepfake videos and face swaps.
Particularly concerning is the fact that accounts created this way have been flagged by the National Crime Agency (NCA) for being more likely to be used for criminal activity.
Separately, casino games developed by software operators licensed by the commission are being made available on unlicensed websites accessible to UK consumers, something the Gambling Commission has highlighted several times in recent months.
The update also covered:
- Money service business activity in remote and non-remote casinos
- Money offered in exchange for personal details and gambling accounts
- Open-loop payment processes
- Terminals used to facilitate payments in land-based casinos
- Changing customer demographics in the land-based casino sector
- Adult gaming centre premises converting to licensed bingo premises
- Application registration cards
Additionally, the publication requires operators to review the lists of "jurisdictions subject to increased monitoring by the Financial Action Task Force (FATF)" and ensure they have effective policies, procedures and controls in place to identify customers and relationships with links to high-risk jurisdictions.
The document includes a long list of advice for operators to follow to ensure they do not expose themselves to these risks and meet their licence requirements.