The Gambling Commission has released an updated version of its casino guidance, bringing it in line with earlier amendments under the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002, and the FCA’s approach to politically exposed persons (PEPs). While many of these issues have been flagged in recent notices, this is the first time they have been consolidated into the formal guidance.
For compliance teams in the gambling sector, the message is clear: scrutiny of AML controls is tightening, thresholds are shifting, and operators must reassess their risk frameworks, particularly around customer due diligence, DAML reporting and B2B partnerships.
Updated PEP guidance
The Commission has aligned its casino guidance with the FCA’s expectations on PEPs. This includes updated language in paragraphs 6.88 and 6.92, reinforcing proportionate risk-based assessments rather than blanket enhanced due diligence.
This mirrors the wider shift in UK financial crime regulation to ensure firms treat PEPs fairly while maintaining robust controls. For casinos, this means reviewing risk-scoring models, customer onboarding processes and the justification for any enhanced checks.
High-risk third countries
The guidance now incorporates the most recent changes to the high-risk third countries list. Operators must ensure their jurisdictional risk assessments and source-of-funds procedures reflect the updated designations.
A prime example of this trend is the Corbett Bookmakers case, where failings in AML controls resulted in a significant fine. This highlights the ongoing focus of UK regulators on addressing source-of-funds weaknesses and insufficient due diligence standards within the industry.
DAML threshold increase: £1,000 → £3,000 (casino sector only)
As of July 2025, the threshold for submitting a Defence Against Money Laundering (DAML) report has increased from £1,000 to £3,000 for casinos.
This shift is significant: it reduces the volume of low-value DAML reports but raises the bar on what constitutes suspicious activity. Casinos will need to recalibrate their internal triggers, retrain staff, and revalidate their SAR workflows to ensure consistency with both the threshold change and the NCA’s expectations.
Increased scrutiny of B2B and white-label partnerships
Paragraphs 1.42 and 2.11 have been revised to explicitly require operators to assess the money-laundering risks posed by:
- Business-to-business relationships
- Third-party suppliers
- White-label partners
This is a notable shift. The Commission is making it clear that AML responsibility cannot be outsourced or diluted in complex operating structures. Where operators rely on technology partners, affiliates or white-label providers, they must ensure those partners meet equivalent AML standards and carry out appropriate oversight.
This aligns with broader enforcement trends globally, including Australia’s growing focus on casino AML failings as part of which new cash restrictions will impact gambling operators in Queensland.
Why this matters for the gambling industry
These updates are not just administrative. They signal that the next phase of UK AML supervision will place greater emphasis on:
- Risk-based decision-making for PEPs
- Jurisdictional awareness tied to high-risk countries
- Greater responsibility for B2B and white-label oversight
- Operational adjustments linked to the DAML threshold increase
With the Gambling Commission continuing to issue high-profile penalties for AML deficiencies, operators must treat these changes as a prompt to update their policies, controls and training programmes. The Corbett Bookmakers enforcement action is a reminder of the consequences of weak monitoring, inadequate customer due diligence and ineffective oversight.
What’s coming next
The Commission has confirmed that a further update to casino guidance will follow once the next round of amendments to the Money Laundering Regulations 2017 is finalised.
For now, casinos should treat the current updates as immediately applicable and begin updating their AML frameworks, training and internal documentation.
