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The UK Gambling Commission has raised the money laundering risk level for gambling software from low to medium, citing B2B supply chains that can place licensed content on illegal websites.
Good To Know
- Gambling software was the only sector to receive a new rating.
- Remote casinos, betting and bingo remain high risk.
- UKGC recently found Evolution games on six unlicensed websites.
Illegal Distribution Raises Software Risk
The 2026 money laundering and terrorist financing assessment covers British gambling activity between April 1, 2023, and October 31, 2025.
Gambling software was the only category to change. The Commission said:
“This is due to the risk posed by business-to-business relationships and the risk of licensed operators supplying software to illegal website operators.”
Suppliers do not always contract directly with an unlicensed casino. Games can pass through aggregators, resellers and other intermediaries before reaching the final website. Weak checks after contract approval can leave developers unable to show where their content appears.
A recent enforcement case shows the regulatory concern. Evolution Malta Holding Limited agreed to pay £4.75 million after UKGC found its games on six unlicensed gambling websites accessible from Great Britain.
Software companies also receive funds from investors and commercial partners. The assessment identifies cryptoassets and businesses offering cryptoasset services as another source of financial exposure.
Key2Law chief executive officer Mykyta Kim said regulators now examine the full payment chain, including who receives funds, converts cryptoassets, holds customer money and performs AML checks.
Kim added:
“Under the post-transition MiCA regime, relying on assurances is no longer enough.”
Suppliers Face A Different Legal Position
Casinos remain the only gambling businesses directly covered by the UK Money Laundering Regulations. Gambling software licence holders also sit outside Licence Condition 12.1.1, which requires covered operators to maintain money laundering risk assessments and controls.
However, software suppliers still have duties under the Gambling Act licensing objectives, the Proceeds of Crime Act 2002 and the Terrorism Act 2000. UKGC can act where a supplier fails to prevent gambling from becoming linked with crime.
The Commission has also increased its work against illegal gambling. Since April 2024, its Illegal Markets team has issued more than 3,100 cease and desist or disruption notices and referred hundreds of thousands of web addresses to search engines.
HM Government has allocated £26 million over three years to support action against unlicensed gambling, including companies that provide games, payments, hosting and other services.
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