UKGC Flags Emerging AML Threats, Including Crypto and Crash Games

The UK Gambling Commission (UKGC) has released updated guidance on emerging risks relating to anti-money laundering (AML) and terrorist financing. 

Companies holding a UK gambling license are required to keep up with emerging risk information published by the Commission. The release of updated guidance serves as a “trigger for operators to review their money laundering and terrorist financing risk assessments and related policies, procedures and controls.” 

The UKGC update from April 2025 highlights 13 broad AML risks:

1. Money service business activity in remote and non-remote casinos.
2. Artificial intelligence used to bypass customer due diligence.
3. Money in exchange for personal details and gambling accounts.
4. Third-party business relationships, including white-label partnerships and investments
5. Open-loop payment processes
6. Licensed software providers’ games on unlicensed websites
7. Cryptoassets
8. Terminals used to facilitate payments in non-remote casinos
9. Changing customer demographics in the non-remote casino sector
10. Adult gaming centre premises converting to licensed bingo premises
11. Crash games
12. Application Registration Cards
13. Jurisdictions subject to increased monitoring by FATF

Several of the above are regarding activities undertaken online and cover emerging trends in technology and consumer behavior. Several have specific applications to the emergence of crypto casinos and offshore gaming sites. 

UK Licensees Offering Games to Illegal Operators

The Commission has pointed to a rise in casino games that are developed by licensed software operators in the UK being available on unlicensed websites that are accessible and target the UK market. It outlines that those undertaking such activity are “at risk of accepting funds derived from criminal activity.” 

The Commission advises operators to “actively monitor their business relationships to ensure that partners are not offering illegal gambling facilities” to the British market. Should there be non-compliance, operators are required to terminate these relationships immediately. “Actively notifying the Commission and presenting a clear and prompt plan to mitigate the issue is a minimum requirement.” 

Growing Interest in Crypto Sparks UKGC AML Concern

Increasing interest in cryptocurrencies within the licensed gambling industry has been noted as an area of concern from a money laundering perspective. The UKGC officially rates crypto as a ‘high-risk payment method.” 

Guidelines also note a large theft of crypto from the ByBit exchange in February 2025. They claim that the group alleged to have undertaken the theft is ” suspected to use complex online money laundering systems, which, in the past, have been thought to include remote gambling operators around the world.” 

The UK regulator has urged vigilance with regard to the use and acceptance of crypto assets. As the number of payment providers that offer crypto payment facilities increases, operators are encouraged to have a “full understanding of the services provided” by their payment providers. 

Additionally, where source of funds checks show that customers’ funds to gamble have come from crypto trading, this should be considered as a high-risk indicator, and sufficient due diligence must be undertaken. 

Crash Games Bring AML Risks

Updated guidance notes that “Crash games have been offered by crypto casinos […] for a number of years.”

It continues: “We have been made aware of an increased interest in crash games within the legal, licensed casino sector, so we are drawing operators’ attention to the risks of this game type.” 

The mechanics of crash games, which allows customers to cash out at any point after an initial bet is made (as the multiplier grows), can allow criminals to “camouflage the high-risk behaviour of cashing out quickly with limited gameplay within the context of the crash game (where these behaviors are inherently more common), and that transactional monitoring controls may not be effective in detecting suspicious activity.” 

The UKGC advises operators to assess the AML risk of any new product they launch. It adds, “Operators must then ensure they have appropriate procedures in place to prevent money laundering.” It suggests using the feed of crash game activity to build into a customer’s overall risk profile.