May 2025

by Andrei Cosma & Adela Nuță

In April 2025, the UK Gambling Commission released a comprehensive update on emerging money laundering and terrorist financing risks across the gambling sector that also outlines current threats and sets Commission’s clear expectations for how operators should respond to such.

Although directed at licensed operators in Great Britain, the Commission’s insights have wider relevance beyond the UK context. They highlight systemic vulnerabilities that increasingly affect gambling markets globally, particularly in jurisdictions such as Romania, where AML compliance frameworks continue to evolve in line with international expectations set by the FATF and the European Union.

Specifically, the update outlines a significant number of emerging risk areas that reflect both regulatory priorities and broader vulnerabilities within the gambling sector, including the continued misuse of MSB services within casinos, the increasing use of AI to forge identity documents and circumvent due diligence, and the exploitation of personal data for fraudulent account creation. Other key concerns include weak oversight of open-loop payment systems, the appearance of licensed games on unregulated platforms, and high-risk activity linked to cryptoasset transactions.

The report also highlights operational blind spots in terminal-based payments, unaddressed shifts in customer demographics, and the laundering potential of crash games. Additional risks relate to the improper acceptance of asylum-related identity cards, and the insufficient vetting of third-party partners and financial inflows.

Together, these findings reinforce the need for dynamic, risk-based AML strategies across the sector.

Although specific to the UK framework, the underlying typologies of the risks identified by the report are not. The convergence of digital gambling, AI manipulation, cryptoassets, and cross-border financial flows means that these risks are inherently transnational. In this sense, the Gambling Commission’s analysis offers practical guidance for AML professionals, regulators, and compliance teams beyond the UK.

For Romanian operators, many of the risks highlighted are increasingly visible within the local market. As such, the UK model can serve as a benchmark for proactive risk mitigation, providing a valuable roadmap for strengthening compliance procedures, internal audit frameworks, and client onboarding protocols.

As a result, the Commission’s update offers a relevant point of reference for operators aiming to align their AML frameworks with emerging international standards.

A more detailed overview of the update is available HERE.

Details about Anti-Money Laundering (AML) are available HERE.