Gambling Commission Suspends Victoria Gate Casino Licence Over AML Failings

The abrupt suspension of the operating licence held by VGC Leeds Limited, which operates the Victoria Gate Casino in Leeds, by the Gambling Commission on 31 October 2025 has cast a sharp spotlight on the vulnerability of the gambling sector to money-laundering risk. The regulator’s use of section 116 of the Gambling Act 2005, alongside references to “effective anti-money laundering policies, procedures and controls,” underscores that even prominent bricks-and-mortar casino operations remain prime targets for illicit finance flows.

The Gambling Commission publicly stated that, as part of an assessment under section 116 of the Gambling Act 2005, the operator was reasonably believed to have failed to uphold licence conditions relating to anti-money laundering. The regulator highlighted two broad areas of concern: the absence of “effective anti-money laundering policies, procedures and controls” and “serious concerns” regarding decision-making processes and the response to identified anti-money laundering and counter-terrorist financing risks. The regulator described these failings as “significant” and constituting a “serious threat” to the licensing objective of keeping crime out of gambling.

While the announcement did not quantify illicit transaction volumes, the operator’s prior history is revealing. In a 2021 regulatory settlement, VGC Leeds was fined for AML failures. That earlier case disclosed that the operator had accepted a customer who lost £275,000 over 22 months without verifying the source of funds, and another who lost £93,294 over 16 months despite inadequate checks. The fine covered both financial gain and penalty, and the operator committed to remedial measures.

The current suspension, rather than a caution or partial sanction, signals that the regulator views the suspected failings as acute rather than limited to discrete historic events. During the suspension, the operator is required to focus on customer fairness and keep stakeholders informed of developments. Meanwhile, the venue remains closed pending the resolution of the review. For AML professionals, the regulator’s emphasis on governance, risk management, and decision-making within the casino environment demonstrates that enforcement action can be triggered where systemic control weaknesses are identified.

Casinos present significant potential for AML exposure due to large-value cash flows, real-time transactions, and interactions with high-volume, high-net-worth, or VIP customers, raising the stakes for source-of-funds (SOF) verification and enhanced due diligence (EDD). Sector-specific guidance often points to non-monetary indicators, such as frequent chip buy-ins, immediate cash-outs without real gambling, or structured deposits designed to avoid reporting thresholds. Regulatory obligations extend beyond transactional controls to include governance oversight, board accountability, and risk culture.

In the earlier 2021 case, the regulator highlighted failures including accepting large losses inconsistent with declared income, reliance on dormant companies or undeveloped income sources, and poor record-keeping of customer interactions—textbook indicators of layered suspect behavior. In the current suspension, the regulator specifically cites failure to maintain and implement policies, procedures, and controls, as well as inadequate governance, risk-management arrangements, and decision-making concerning AML/CTF risks. These weaknesses are major red flags: governance failings indicate controls were not embedded or overseen, decision-making failings suggest management did not respond appropriately to identified risks, and policy/procedure failings suggest regulatory obligations were not translated into practice.

Key AML controls for casinos include robust customer risk segmentation, rigorous source-of-funds and source-of-wealth checks, ongoing transaction monitoring aligned with gambling flows, anomaly detection, alerting governance when VIPs exhibit abuse signals, exit controls to track cash-out and chip-cashing, and board-level ownership of AML/CTF risk. Where these elements are weak, regulators have demonstrated they will move swiftly to act.

The Victoria Gate case provides immediate lessons for AML professionals. Governance counts: it is insufficient to merely draft AML policies; senior management and the board must demonstrate oversight through periodic assurance, internal audits, scenario-testing of high-risk customer behavior, and clear escalation mechanisms. Customer risk assessment must be dynamic and contextualized, with VIPs, high-loss patrons, and introducers triggering enhanced due diligence, particularly source-of-funds checks that are meaningful, timely, and properly documented. Transaction monitoring must be scenario-based, reflecting casino-specific behaviors such as rapid chip purchases, cash-ins and outs, gaming velocity, and win/loss ratios. Record-keeping and audit trails must be impeccable, with high-risk decisions documented, reviewed, and escalated as necessary. Compliance functions must be adequately resourced, trained in gambling-specific AML risks, and operate independently of business-line incentives.

The suspension also highlights operational risks: a licence suspension, rather than a fine, threatens the business’s continuity. Operators must plan remediation, manage stakeholder communications, and address reputational and license-renewal implications. The case emphasizes that historic failings, such as those leading to the 2021 fine of £450,000 for weak SOF checks and poor interaction records, can compound regulatory scrutiny.

From a broader perspective, the suspension reinforces that AML oversight in the UK gambling sector is evolving, and enforcement is not limited to financial institutions. Casinos are increasingly treated like financial entities regarding risk exposure, requiring a full suite of AML/CTF safeguards: risk-based customer due diligence, ongoing monitoring, governance oversight, scenario modeling, reporting suspicious activity, and senior-management accountability. Failings can also affect associated partners, including payment processors, gaming suppliers, accountancy intermediaries, and VIP introducers, highlighting the need for extended-enterprise risk assessment.

AML and CFT professionals in gambling should act immediately by conducting full governance reviews, revisiting customer risk frameworks, updating casino-specific transaction-monitoring scenarios, strengthening document storage and audit trails, reviewing staff training, considering third-party risks, scenario-testing business-continuity plans for licence suspension, and benchmarking against regulatory expectations. The suspension of the Victoria Gate Casino licence underscores that regulators will not wait for a public scandal to act: they will intervene where control frameworks appear insufficient, demonstrating the critical importance of embedding robust AML controls throughout casino operations.

By fLEXI tEAM