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FATF Publishes New Financial-Crime Risk Indicators for Gaming and Gambling

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Altay
Altay Celikkaya
Content Manager
Updated:
Reading Time: 3 minutes

The Financial Action Task Force has published new risk indicators to help governments, regulators and businesses identify financial-crime risks across gaming and gambling. Released on 9 September, the official FATF publication draws on contributions from more than 80 jurisdictions and marks FATF’s first detailed examination of risks linked specifically to online and illegal gambling. It covers money laundering, terrorist financing and proliferation financing across casinos, betting, online gaming, payment channels and related service providers. The publication shifts the focus towards practical behavioural, transactional and ownership signals that compliance teams can monitor.

French flag displayed beside the FATF logo, with Paris skyline in the background.

Regulation & Compliance

Key Takeaways From FATF’s New Gambling Risk Indicators

  • Gambling accounts may be used to move funds through deposits and withdrawals with little or no meaningful play.

  • Repeated small transactions can be structured to avoid internal or regulatory detection thresholds.

  • Multiple accounts, identities or payment methods can indicate attempts to obscure the source or ownership of funds.

  • Customer and payment information that does not match may require enhanced scrutiny or escalation.

  • Coordinated betting, suspicious ownership structures and links to cyber-enabled fraud can increase financial-crime exposure.

Transaction Patterns Move to the Centre of AML Monitoring

FATF identifies warning signs that can be detected within normal operator and payment workflows. These include deposits from multiple third-party accounts, withdrawals soon after deposits without proportionate gambling activity, frequent use of different payment methods, and activity spread across accounts linked by devices or IP addresses. It also highlights unusually large or coordinated bets connected with events flagged for possible competition manipulation.

For compliance teams, the challenge is connecting alerts to documented investigation and escalation processes. The recent FINTRAC penalties against two Canadian gaming corporations showed how suspicious transaction reporting and wider AML controls can become enforcement issues when risk indicators are not handled effectively.

The same principle applies to customer identity. Discrepancies between a registered player and the person or account funding gambling activity can point to third-party payment use, identity abuse or money movement on behalf of another party. FATF also flags suspicious identity documents and attempts to bypass due diligence.

Offshore Operators and Supply Chains Expand the Risk Perimeter

The report identifies illegal and unlicensed offshore gambling as a major risk, noting that such operators may present themselves as legitimate businesses while offering anonymity and cross-border payment options. That assessment arrives alongside research estimating a $50 billion global unlicensed online gambling market, increasing attention on infrastructure supporting unauthorised operators.

FATF’s analysis goes further by linking gambling exposure to the wider digital economy. E-wallets, mobile money, virtual assets, software providers, digital marketplaces and social media can form part of the transaction or distribution chain. Differences between national licensing and AML frameworks can create gaps that make supervision and information sharing more difficult.

The supplier side is therefore harder to separate from financial-crime controls. The UK Gambling Commission’s decision to raise the gambling software sector’s AML risk rating to medium followed a £4.75 million Evolution settlement involving weaknesses in risk assessment, customer due diligence and supply-chain oversight. For B2B providers, knowing who receives products, where they are accessible and how partners are monitored is increasingly part of the compliance perimeter.

FATF President Giles Thomson said:

Without robust safeguards, these sectors can be attractive gateways for fraudsters, professional money launderers and organised criminal networks.

Risk-Based Supervision Will Shape the Regulatory Response

FATF is a global standard-setter rather than a gambling enforcement authority. The report does not introduce binding gambling rules, order national regulators to impose specific measures or establish that any individual risk indicator proves criminal activity. National authorities will decide how the findings affect licensing, supervision, reporting and enforcement within their own legal frameworks.

The direction of travel is already visible in Europe. The EU Anti-Money Laundering Authority’s consultation on risk-based gambling supervision proposes sector-specific assessment factors such as transaction volumes, payment methods, onboarding channels and geographical reach. FATF’s indicators give regulators and operators another global framework against which those controls can be tested.

For operators, payment providers and B2B suppliers, the immediate task is to compare existing monitoring systems with the new indicators and identify gaps across customer behaviour, transactions, ownership and third-party relationships. The value of the FATF publication lies less in creating a new compliance obligation than in establishing a clearer international benchmark for recognising where financial-crime risk may be building.