10 September 2026: FATF publishes new report on the Risks of Gaming and Gambling
The Financial Action Task Force (FATF) has published a new report on the risks of gaming and gambling, providing an updated, global assessment of money laundering (ML), terrorist financing (TF) and proliferation financing (PF) risks affecting the sector.
The publication represents the first FATF report focused on the vulnerabilities and threats within the gambling sector since the joint FATF/APG 2009 work relating to the casino sector. The industry has evolved considerably through the growth of online gambling, cross-border business models and delivery channels, technological innovations and the increasing diversity of payment methods.
FATF’s work examines a broad range of gaming and gambling activity including online and terrestrial casinos, sports betting, lotteries, bingo, and online video gaming. It also considers the interaction of gaming and gambling services with wider payment ecosystems, social media platforms and other digital services. The analysis identifies a range of threats and MT/TF/PF indicators across both online and land-based gambling platforms and establishments, including links to organised crime groups, cyber-enabled fraud, corruption, professional ML networks, complex structures, high-risk jurisdictions, payment intermediaries and broader ecosystem risks.
As a result of this work, the FATF has published a comprehensive set of red-flag indicators designed to assist public sector authorities and private industry in identifying potential ML/TF/PF risks. The indicators cover both online and terrestrial gambling environments and span across a range of risk areas, including:
- Customer behaviour and profiles
- Online account activity
- Betting behaviour
- Payment methods and transactions
- Product and platform features
Many of the themes and indicators identified through the FATF’s recent work are already recognised and reflected within the Isle of Man National Risk Assessment for Gambling Sector. The FATF publication highlights that gaming and gambling businesses are now part of a broader interconnected value transfer ecosystem consisting of a range of actors and services, some of which may sit outside national AML/CFT frameworks and potentially elevate ML/TF/PF risk exposure. This reinforces the importance of considering risks that may arise through wider business relationships and third-party service providers.
The FATF’s analysis also emphasises the importance of understanding ownership and control arrangements, especially where structures are complex, opaque or involve higher-risk jurisdictions. Several of the identified risk indicators relate to the use of complex legal arrangements, and the potential for criminal actors to conceal ownership or influence through corporate structures. A number of the risk indicators also reflect the vulnerabilities associated with complex and cross-border payment methods, including the use of virtual assets, payment intermediaries and unlicensed or unregistered remittance providers.
How should Operators Use this Publication?
The GSC encourages licence holders to review the publication and consider whether its findings and risk indicators should be incorporated across:
- BRAs;
- CRAs;
- Transaction monitoring systems;
- Account and activity monitoring systems;
- Escalation and reporting procedures;
- Staff training programmes;
- Wider AML/CFT frameworks;
The FATF also highlights the importance of public-private collaboration in identifying and responding to the evolving financial crime threats within the industry. The GSC encourages all licence holders to continue engaging with public sector authorities through the Isle of Man Financial Crime Partnership and the GSC’s AML Forum, as well as reporting any new and emerging ML/TF/PF trends, typologies or indicators to the Isle of Man Financial Intelligence Unit.