UK Gambling Commission Flags Insufficient White-Label Partnership Scrutiny as Money Laundering Risk in 2026 Assessment

The UK Gambling Commission published its 2026 money laundering and terrorist financing risk assessment report, drawing on data from 1 April 2023 to 31 October 2025. Remote and non-remote casinos together with betting activities remain the subsectors with the highest risk profiles, while the National Lottery and society lotteries stay low risk. The report underscores operator failings and specifically calls out insufficient scrutiny of white-label partnerships and business-to-business relationships as a contributing vulnerability.

Remote casino gross gambling yield reached £5 billion between April 2024 and March 2025, with slot games accounting for £4.2 billion. Remote betting yielded £2.6 billion and non-remote betting £2.5 billion, including only £28 million from on-course betting. The Commission’s methodology applies a likelihood × impact formula, assigning high ML risk to peer-to-peer products such as poker and betting exchanges. The gambling software sector moved from low to medium ML risk, reflecting cross-border supply chains and the potential for licensed software to reach unlicensed operators.

Scale of Payment Trends and Operator Control Gaps

Payment methods loom large in the risk picture. The Commission highlighted rising use of e-wallets, pre-paid cards and cryptoasset-linked funds in remote sectors, alongside complex multi-method systems that aid concealment. Criminal techniques have grown more sophisticated, employing deepfakes, face-swap videos and AI-generated false identity documents to defeat customer due diligence. Operator-side shortcomings persist across subsectors: deficient AML/CTF policies, poorly trained personnel, inadequate thresholds and weak monitoring of linked accounts.

Casinos providing money service business functions face separate exposure. In 2024, around 3% of remote casino licence holders and 56% of non-remote holders offered such services, with related activity estimated at approximately £70 million. Indicators include multiple small foreign-exchange transactions, high-risk jurisdiction dealings and mismatched currency flows. Illegal gambling has risen sharply, often involving unregulated casinos accepting cryptoassets and using VPNs to obscure data. The UK government has allocated £26 million over three years to the Commission to tackle these markets and payment vulnerabilities, as reported by iGaming Business.

The White-Label Scrutiny Imperative

White-label partnerships escaped direct impact in the recent DCMS consultation on banning unlicensed gambling sponsorships, which relies on secondary legislation under the Gambling Act 2005. Yet the Commission’s assessment treats lax review of these arrangements as a distinct ML risk contributor. This gap sits alongside technical vulnerabilities such as automatic ticket redemption systems and self-service betting terminals.

After decades observing regulatory convergence in licensed markets, I see this as a point where client-partners must tighten B2B onboarding and ongoing monitoring. The report’s emphasis on white-label exposure, paired with the fresh funding for enforcement, signals that regulators will not tolerate structural blind spots. Operators who treat partnership scrutiny as an afterthought invite exactly the enforcement pressure the Commission is now resourced to apply.

Reporting: Lack of white-label partnerships scrutiny is a money laundering risk, reports GC (igamingbusiness.com)