Gambling Commission Heads Towards Real-Time Payment Screening
09 October 2026
The UK Gambling Commission is sharpening its expectations of online gambling operators on anti-money laundering due diligence. The intense scrutiny is being driven by an evolving threat from illegal gambling sites, increased use of cryptoassets, weak third-party controls, and a rise in risks associated with gambling software.
The regulator has doubled down on existing requirements and is poised to push for major upgrades in real-time transaction monitoring.
Existing Rules
The Gambling Commission has long held that critical responsibility for customer checks rests with gambling operators, not with third-party payment processors.
Under Licence Condition 12.1.1, gambling businesses must conduct risk assessments covering money laundering and terrorist financing and have adequate policies, procedures and controls in place to mitigate those threats.
Operators must independently check customer information and verify the source of customer funds, rather than taking third-party reports at face value. The Commission has made clear that outsourcing of anti-money laundering due diligence to unregulated third parties would not meet its requirements.
Recently, the regulator has emphasized the need for stronger in-play monitoring of customer activity to detect and intercept harmful behavior. It also put in place requirements for operators to display to customers real-time information on their net spend and time gambling, but made clear that these consumer safety protections are distinct from the AML rules.
Emerging Risks
The Gambling Commission's 2024 assessment significantly revised the inherent money laundering risks for the gambling software sector, upgrading it from low to medium risk overall. The Commission was driven to that shift by two interconnected factors: the expanding role of software businesses in relationships with third-parties, and reports that licensed software operators are occasionally supplying to illegal unlicensed websites.
The risks from illegal gambling sites in general, the Commission said, have not changed - but the threats they pose are becoming more serious. Illegal sites are not supervised, do not meet the Commission's license conditions or comply with UK Money Laundering Regulations. The Commission said in 2024 that many of these sites have begun taking payments via cryptoassets, which the regulator has flagged as high-risk for money laundering and terrorist financing.
In its 2024 Communiques, the Commission disclosed that the UK government had allocated £26m over a three-year period to strengthening the regulator's ability to disrupt illegal gambling market. The money was to fund enforcement action, investigations, and awareness-raising efforts.
The Changes
Despite the heightened emphasis on stronger AML procedures, the latest materials from the Gambling Commission,"2024 Money Laundering and Terrorist Financing Risks within the British Gambling Industry", do not confirm the introduction of a mandatory real-time due diligence rule for payments. The Commission has in the past discussed the use case for in-play monitoring and real-time spend and time tracking, but had not mandated it as a formal requirement across the board.
If the Gambling Commission is ultimately to confirm an enhanced standard, it is likely to take the form of a more fulsome requirement for payment screening and a shorter timeframe within which to complete customer checks.
Operators may need to revise internal controls, integrate real-time transaction and payment data into their monitoring systems, and develop new processes to enable faster and more efficient due diligence.
The approach to partnership agreements may also require revision, in light of the increased focus on relationships between gambling software suppliers and illegal operators.
No Insiders and No Systemic Threats
The Gambling Commission reiterated that it would hold operators accountable for meeting anti-money laundering obligations, despite the rising risks from crypto payments and illegal sources. In communicating its expectations, the Commission took care to note that adding this regulator to the expectation would "allow more time for operators to develop adequate solutions".
The regulator opted to take a more moderated approach in its consumer-focused approach of financial vulnerability checks, refining its rules to minimize the extra friction for UK players.