Insights The Gambling Commission updates its ML/TF Risk Assessment – action needed


The Gambling Commission has published an update to its Money Laundering (ML) and Terrorist Financing (TF) risk assessment.

In the Commission’s words, the ‘purpose of this risk assessment is to:

  • provide a resource for the industry in informing their own ML and TF risk assessments
  • provide the Commission’s support to HM Treasury’s National Risk Assessment
  • inform and prioritise our licensing, compliance, and enforcement activity to raise standards in the industry….’.

Under Licence Condition, operators must ‘ensure that …. policies, procedures and controls are implemented effectively, kept under review, revised appropriately to ensure that they remain effective and take into account any applicable learning or guidelines published by the Gambling Commission from time to time.’

The 2023 Risk Assessment details ‘updated risks that gambling businesses can encounter’, and that must be taken into account and effectively mitigated by licensees in their revised risk assessments.

As such, it is expected that operators will review and, where appropriate revise, their own risk assessments as a consequence.

The 2023 Risk Assessment can be found here.