Terrorist Financing Focus: UK Regulator Raises Casino Risk Level

The British gambling regulator has published its 2026 risk assessment, sounding the alarm over evolving threats. In a comprehensive review of money laundering (ML) and terrorist financing (TF) vulnerabilities, the commission highlights that the risk landscape for licensed operators has intensified significantly. Of particular concern is the reclassification of the TF risk level for the casino sector from low to medium. This assessment is based on data collected between April 2023 and October 2025. The authorities view technological progress as a double-edged sword, as artificial intelligence is increasingly being used to bypass control mechanisms.

A central point of the report is the warning against deepfakes and AI-generated identity documents. Criminals are more frequently using face-swap videos to deceive the customer due diligence (CDD) processes at online casinos. Simultaneously, the pressure from illegal websites, which facilitate illicit financial flows in business-to-business relationships, is growing. The regulator emphasizes that peer-to-peer models, such as poker and betting exchanges, show a high risk for money laundering. These products are under close scrutiny in both digital and terrestrial environments.

Numbers and facts

The economic scale of the industry is immense. Between April 2024 and March 2025, the gross gambling yield (GGY) for remote casinos reached 5 billion GBP. The lion's share was contributed by slot games, accounting for 4.2 billion GBP. In contrast, non-remote betting generated 2.5 billion GBP, with only 28 million GBP coming from on-course betting. The role of money service business (MSB) functions in casinos is also noteworthy. In 2024, approximately 56 percent of non-remote license holders operated MSB services like currency exchange, with an estimated activity of 70 million GBP. The commission identified risky patterns here, such as numerous small foreign exchange transactions or deposits from high-risk jurisdictions.

Background

According to the report, white-label partnerships represent a massive problem. In this model, a partner uses the license of another company to operate its own brand. The Gambling Commission found that primary licensees often exercise inadequate oversight over their partners. A prominent example is the case of FSB Technology, which had to accept a settlement of 634,300 GBP after severe failures in partner monitoring were discovered.

"We found that whilst FSB did have contractual arrangements in place with its ‘white label’ partners, it did not take sufficient action to ensure they were following the Licence Conditions and Codes of Practice (LCCP)." - Gambling Commission Spokesperson

One customer was able to lose approximately 282,000 GBP within 18 months at one of these partners without the source of funds being adequately verified. Furthermore, marketing emails were sent to over 2,300 individuals who had already self-excluded. Such incidents demonstrate that contractual clauses alone are insufficient if practical control and staff training are lacking.

Why it matters for German players

This report is an important signal for German players. The German Interstate Treaty on Gambling 2021 (GlüStV 2021) already sets extremely high barriers to minimize exactly these types of risks. The central supervisory authority, GGL, strictly ensures that providers are on the official whitelist. Mechanisms such as the 1,000 EUR monthly deposit limit across all providers and the 1 EUR per spin limit for virtual slots serve directly to prevent money laundering and excessive gambling behavior. The LUGAS system also ensures that player identities are verified, making the use of deepfakes significantly more difficult compared to the unregulated market. German customers should exclusively play with GGL-licensed providers, as only there are the strict German AML (Anti-Money Laundering) guidelines enforced.

What it means for GGL-licensed casinos

The findings from the UK are likely to influence the work of the GGL in Halle. In particular, the warning about AI manipulation during verification is a heads-up for all IT departments of German licensees. Anyone operating in Germany must prove that their systems are resistant to modern fraud tactics. The GGL requires seamless evidence of the source of funds once certain thresholds are crossed. While MGA or Curacao casinos often stand out due to lax checks and the acceptance of cryptocurrencies, this remains strictly prohibited in Germany. The British report confirms that cryptocurrencies often serve as a conduit for organized crime, which is why the German ban on these payment methods in the legal market serves an important protective function.