The UK Gambling Commission has raised the money laundering risk rating for gambling software suppliers from low to medium. It is the only risk-rating change in the regulator's newly updated 2026 assessment, published on 30 July, three years after the previous version.
The Commission pointed to two emerging concerns driving the broader review. The first is AI-enabled identity fraud, including AI-generated false documents, deepfake videos, and face swaps designed to bypass know-your-customer checks. The second is business-to-business links between licensed suppliers and illegal gambling operators.
The regulator said software businesses may end up connected to black market operators through software sales, even without knowingly dealing with them directly. Weak oversight of third-party contracts was cited as a factor. The report also flagged that some suppliers receive funds in cryptoassets or from businesses involved in cryptoasset activity.
A new high-level risk was also added covering casinos acting as Money Service Businesses, where foreign customers use bank cards that would not otherwise work in the UK to access gambling funds. AML consultant Nigel Harvey said the structure raises real source-of-funds concerns.
Harvey also welcomed the clearer separation between supplier risks and operator risks in the new assessment, saying it helps businesses understand what to document for their own exposure. He added that consolidating guidance from other sources into one risk assessment is a helpful step, and expressed hope the Commission's compliance managers will apply the framework consistently going forward.
For software suppliers and B2B platform providers serving UK-licensed operators, the medium risk classification is a signal to review third-party contract oversight and client due diligence processes.
