The Gambling Commission has upgraded the anti-money laundering risk for gambling software suppliers from low to medium in its 2026 money laundering and terrorist financing risk assessment.

The change was made after the regulator identified risks posed by business-to-business relationships and the risk of licensed operators supplying software to illegal website operators.

“The sale of software to illegal website operators may not be by a licensed operator directly but may result from insufficient monitoring of third-party contracts and activity,” states the update. “As software supply can involve cross-border arrangements with multiple parties, there is a greater potential for money laundering exploitation.”

“Gambling software businesses may also receive funds in the form of cryptoassets or from businesses offering cryptoasset activity. This has been noted as occurring through business relationships and investments.”

The increase was partly due to the perceived risk of cryptocurrency transactions and operators performing inadequate due diligence checks on third party business relationships, with the Commission citing a case studies whereby a gambling software company received a loan where the ultimate source of funds was revenue from a remote casino offering cryptoasset facilities. 

“Further investigation showed that the casino was encouraging circumvention of geo-blocking controls by customers by describing how this can be achieved.”