FATF Identifies Money Laundering and Terrorist Financing Risks Across Gaming and Gambling Sectors

The Financial Action Task Force (FATF) has identified a range of money laundering, terrorist financing and proliferation financing risks affecting the global gaming and gambling sectors, including casinos, sports betting, online gambling, lotteries and online gaming.

The findings were published on September 9, 2026, following an assessment of developments across the sector. The review covers both land-based and online activities and examines the increasing use of digital platforms, cross-border transactions and new payment methods.

According to the findings, the global expansion of gaming and gambling markets, combined with increased digitalisation, has created additional opportunities for criminal exploitation. Online platforms allow transactions to take place rapidly across borders and can provide access to a wide range of payment channels.

The assessment covers casinos, gambling and online gaming platforms, payment channels, illegal operators and their connections with the wider financial system. It also identifies risk indicators that authorities and businesses can use when assessing potentially suspicious activity.

Online casinos and sports betting platforms are among the areas identified as particularly exposed to financial crime risks. Transactions can involve deposits and withdrawals even where there is limited or no significant gambling activity. This can create circumstances in which gambling accounts are used primarily to move funds rather than to participate substantially in gambling.

The findings also identify the use of multiple smaller transactions as a relevant risk indicator. Funds may be divided into amounts below thresholds that could otherwise trigger additional customer identification or anti-money laundering controls. This practice, commonly referred to as “smurfing”, is identified as one of the methods that can be used to move funds through gambling platforms.

The FATF has also identified risks arising from the ownership and control structures of gambling operators. Complex corporate structures can make it more difficult to establish the ultimate owners of gambling businesses. In some cases, the ultimate owners of gambling platforms may have links to organised criminal groups.

The new assessment takes account of the continued growth of online gambling and gaming. Digital platforms can provide access to customers in multiple jurisdictions and may use payment services capable of transferring funds internationally.

The FATF has identified payment methods as an important component of the changing risk environment. Digital payments can facilitate rapid movement of funds and may involve several jurisdictions and service providers in a single transaction.

The assessment also covers illegal gambling operators. Such businesses can operate outside regulatory frameworks and may have different levels of customer identification, transaction monitoring and reporting obligations from licensed operators.

The FATF's review considers the relationship between illegal operators and the broader financial system, including the payment channels through which gambling-related funds can enter or leave regulated financial institutions.

The report covers both traditional gambling activities and newer forms of online gaming. Its scope includes physical casinos, online casinos, sports betting, lotteries, other gambling activities and online and mobile gaming.

The FATF has also identified risks associated with the use of third-party payment arrangements. Gambling transactions can involve payment providers, banks, electronic money institutions, virtual asset-related services and other financial intermediaries.

The number of parties involved in a transaction can vary depending on the gambling platform, jurisdiction and payment method. The FATF's assessment therefore considers the wider financial ecosystem supporting gambling and gaming activities rather than only the operator itself.

The findings identify terrorist financing and proliferation financing alongside money laundering. The assessment therefore covers three categories of financial crime risk rather than focusing exclusively on the laundering of criminal proceeds.

The FATF's findings are based on information collected from jurisdictions and other stakeholders concerning the operation and risks of gaming and gambling markets. The assessment reflects changes in the sector since earlier FATF work examining vulnerabilities associated with casinos and gaming.

The organisation's earlier work on casinos and gaming examined vulnerabilities associated with physical casinos. The latest assessment expands the scope to reflect the growth of online gambling, digital platforms, payment technologies and illegal online operators.

Among the risk indicators identified in the new assessment are transactions that do not correspond with a customer's apparent gambling activity, multiple deposits or withdrawals involving smaller amounts, and activity involving complex ownership structures.

The FATF has also identified cross-border activity as an important feature of the current gaming and gambling environment. Online services can allow customers, operators, payment providers and other parties to be located in different jurisdictions.

The organisation's findings indicate that this international structure can create additional challenges for authorities because financial activity may involve several jurisdictions and regulatory frameworks.

The assessment comes as online gambling continues to expand internationally and gambling operators increasingly rely on digital payment systems. The FATF has stated that the combination of market growth, online platforms and payment methods capable of facilitating rapid and potentially anonymous cross-border transactions has created new opportunities for criminal abuse.

The report does not state that gaming or gambling activities are inherently illicit. Instead, it identifies particular circumstances and transaction patterns that may indicate increased exposure to money laundering, terrorist financing or proliferation financing.

The findings also cover the use of gambling accounts for purposes other than gambling. Where funds are deposited and withdrawn without corresponding gambling activity, the transactions may represent a relevant risk indicator under the FATF's assessment.

The identification of “smurfing” as a risk indicator relates to the structuring of transactions into smaller amounts. According to the findings reported from the FATF assessment, this can be used to avoid thresholds associated with customer due diligence or anti-money laundering controls.

Ownership structures are another area addressed in the findings. The FATF notes that complex ownership arrangements can make it more difficult to identify the individuals ultimately controlling gambling platforms, and that some ultimate owners may have connections to organised crime.

The assessment also takes account of illegal gambling businesses and their interaction with regulated financial services. Illegal operators can nevertheless require access to payment systems and other financial services to receive deposits and process withdrawals.

The FATF's publication provides a set of risk indicators intended to support the identification and assessment of these activities. The indicators cover different types of gambling, online activity, payment methods and relationships with the wider financial system.

The findings were released on September 9, 2026, as part of the FATF's work on emerging money laundering and terrorist financing methods and vulnerabilities. They represent the organisation's latest assessment specifically addressing gaming and gambling activities.

The publication covers a sector that has undergone substantial technological and commercial changes since earlier assessments. Online platforms, mobile gaming, digital payments and international access now form a significant part of the global gaming and gambling environment considered in the report.

The FATF's latest findings therefore identify a range of financial crime risks associated with the modern gaming and gambling sector, including the movement of funds through gambling accounts, structured transactions, complex ownership arrangements, illegal operators, cross-border activity and the use of rapidly transferable payment methods. The assessment covers money laundering, terrorist financing and proliferation financing and provides risk indicators for activities across both physical and online gaming and gambling markets.

By fLEXI tEAM