Richard Bradley, partner on the gambling team at licensing law firm Poppleston Allen, gives Coinslot readers the ins and outs of new AML and terrorism best practice
The Licence Conditions and Codes of Practice (LCCP) and Gambling Commission guidance are an integral part of the regulatory framework governing all Gambling Commission licensed businesses. I am sure for many operators the fact that the LCCP and Commission commentary are regularly reviewed and updated does create an element of pressure and at the very least an administrative burden depending upon the change. However, it is important to keep up to date with any LCCP changes or recommendations to ensure that internal processes and records are updated accordingly, particularly as we are seeing a rise in land-based assessments and enforcement.
Under Licence Condition 12.1.1, all licensees must conduct an anti-money laundering and terrorist financing risk assessment. The assessment must be kept under regular review and we recommend this is completed at least on an annual basis, incorporating version control, highlighting what, if any, changes are made. Assessments should adapt to operational changes, such as new products, services and payment methods and also consider potential changes to customer risk and area profiles and other emerging risks.
Operators are obliged to take into account any guidance published by the Gambling Commission, including any emerging money laundering and terrorist financing risks that it identifies within its own assessment of the industry. Not all risks identified by the Commission may be of relevance to your operation, but internal assessment should identify and consider all potential risks, even where ultimately dismissed.
In October 2025, the Gambling Commission published a further edition of its ‘Emerging money laundering and terrorist financing risks’, which included the ‘high-risk’ associated with the use of pre-paid payment methods. This is due to a number of factors, such as the ability to pre-pay using cash and possibly credit cards, which are of course prohibited, and also potentially crypto assests.
Pre-payment technology also introduces potential complexity regarding an assessment of customer source of wealth and funds and could require payment of winnings to another card or account. Operators should evaluate the nature of any pre-payment technology used within their premises and consider the risk profile of their customers to ensure the effective operational controls and safeguards are implemented.
The prohibition on the use of credit cards is a critical factor as the Gambling Commission has been clear that any prepayment methods should be able to block these payments.
Operators are also reminded that where there are changes to the methods by which they accept payments from customers, who are using their gambling facilities, a key event must be submitted to the Gambling Commission as soon as reasonably practicable and in any event within five working days of the licensee becoming aware of the event’s occurrence (Licence Condition 15.2.1(8). The Gambling Commission expects to be provided with the type of payment method, the provider and how the payment was assessed in the money laundering and terrorist financing risk assessment.
The Gambling Commission also recently updated its guidance on ‘The Prevention of money laundering and combating the financing of terrorism’, which should be considered.
Yet another review!
Richard Bradley said……
“All licensees must conduct an anti-money laundering and terrorist financing risk assessment. The assessment must be kept under regular review and we recommend this is completed at least on an annual basis, incorporating version control, highlighting what, if any, changes are made……
With new emerging risks and guidance now published, what must operators do?
Gambling Commission publications must be taken into account to ensure that all potential risks have been identified and addressed in internal assessments. Failure to do so would be considered in any Gambling Commission compliance assessment and any potential enforcement action taken.
Whilst some of the above may feel like paying lip service to an administrative process, the important factor is that business risk assessments should guide operational policy and procedure, enabling a focus on priority risks presented. Payment methods are relevant when assessing customer risk profiles and help direct appropriate ‘know your customer’ checks. If a customer is presenting as a higher risk, it may be appropriate to obtain further information, such as where the customer funds have come from, to ensure that sufficient checks have been completed.
We know it can be a burden to keep up to date with all the Gambling Commission’s guidance and updates, however minor, but it does regularly publish updates and commentary and I would encourage licensees to subscribe to the Gambling Commission’s e-bulletin. Paperwork is not always the most exciting of jobs, but if it keeps your premises running smoothly, limiting the risk of money laundering within your premises and keeps the Regulator happy, this should be beneficial for all.
If your risk assessment has not been updated for a while as you have not made any fundamental changes to your operation in some time, now would be a good opportunity to consider some not so exciting bed time reading and update your assessments and policies where relevant.
