Since 2025, regulatory expectations for gaming and gambling operators have tightened significantly in key markets, including the UK and the EU, particularly around customer due diligence and ongoing monitoring. These shifts reflect a rapidly changing risk landscape marked by cross‑border digital gambling, the use of virtual assets and cryptocurrencies, and increasingly sophisticated identity fraud, including synthetic identities and deepfake‑enabled impersonation.
In this article, Mario Levin outlines prominent red flags for money laundering in the gambling sector, explores the convergence between gambling, cyber‑enabled fraud and human trafficking, examines how organised crime activity in Southeast Asia has created regulatory challenges for UK gambling brands (and their sponsored Premier League football clubs), and concludes with practical recommendations for gambling operators and their business partners.
Why gambling attracts money launderers
Gambling is defined as staking of money on events of chance or skill, with familiar examples including casinos, sports betting and lotteries, all characterised by the potential for financial gain or loss. E‑gambling brings these activities online, enabling players to bet or play casino‑style games from almost anywhere, often with greater speed and perceived anonymity than in land‑based venues. At the same time, traditionally skill‑based gaming has begun to converge with gambling, through mechanics such as loot boxes and cash‑prize tournaments that replicate betting dynamics, blurring both regulatory and behavioural boundaries. From a financial crime perspective, the key distinctions between gaming and gambling lie in the regulatory perimeter, the value and traceability of cash flows, and the specific typologies criminals use to launder illicit funds.
While gaming often involves no money at all, gambling is inherently cash‑ and transaction‑intensive, with high‑value, rapid and repeat flows that can be difficult to distinguish from legitimate play. National gambling regulators such as the UK Gambling Commission (UKGC) and the Isle of Man Gambling Supervision Commission (IoMGSC) classify many gambling products or business models as higher risk for money laundering and require enhanced controls from operators, while industry bodies such as the European Gaming & Betting Association (EGBA) acknowledge these heightened risks and provide guidance on appropriate AML controls.
One of the most well-known money laundering techniques in gambling is the conversion of illicit cash or digital assets into apparently legitimate “winnings”: criminals deposit funds, conduct limited low‑risk play, then withdraw or cash out, seeking to create a plausible audit trail. Online gambling amplifies the vulnerability to this practice by combining global reach, instant deposits and withdrawals, and complex payment chains, often involving e‑wallets, prepaid instruments and virtual assets. Where customer identity, device data and geolocation are not rigorously verified, criminals can layer funds through multiple accounts, jurisdictions and currencies before re‑entering the regulated financial system. This is why the UKGC’s 2023 assessment classifies remote gambling products such as remote betting and casinos as presenting a high money‑laundering risk, and why the European Commission’s latest Supranational Risk Assessment rates online gambling at the highest money‑laundering and terrorist‑financing risk level, with both bodies expecting robust customer due diligence and ongoing monitoring from operators.
Customer‑driven money laundering: key red flags
Two distinct scenarios are common when discussing money laundering in the gambling sector. In the first, more ‘classic’ scenario, the operator is not knowingly complicit, but its online or land‑based offerings are exploited by criminal actors. Typical red flags include:
- Players’ reluctance or refusal to provide reliable identification, including inconsistent or incomplete details, multiple accounts under similar information, or activity originating from high‑risk jurisdictions or through anonymising tools such as VPNs.
- Repeated high‑value deposits or chip purchases that are inconsistent with a customer’s known profile or declared source of wealth, especially when linked to multiple payment cards, wallets or crypto addresses with no obvious economic rationale.
- Minimal or low‑risk gameplay combined with significant cash‑in and cash‑out activity, where funds transit the platform quickly with little genuine betting behaviour.
- Transaction structuring, such as multiple deposits or chip purchases just below reporting thresholds, or dispersed micro‑payments from a web of instruments that appear designed to avoid detection.
- Unusual betting or withdrawal patterns, including sudden switches between games, erratic stakes, frequent use of linked accounts or rapid transfers between players that suggest coordination rather than recreational play.
In practice, these signals rarely appear in isolation. It is the combination and persistence of behaviours, analysed over time and across different products and payment channels, that should trigger the operator’s escalation, enhanced due diligence and, where appropriate, suspicious activity reporting.
When the operator or insiders are the risk
In the second scenario, actors within the gambling business itself may facilitate illicit finance, whether through weak governance, inadequate oversight of partners or, in the most serious cases, deliberate misconduct. For banks and other financial institutions, as well as commercial counterparties working with gambling operators or with individuals whose wealth stems from the sector, key red flags include:
- Unexplained or weakly evidenced sources of wealth or funds for owners or senior principals of the gambling business and for high‑value patrons, particularly where lifestyles, investment levels or transaction volumes materially exceed known legitimate income.
- Complex ownership structures involving shell or shelf companies, offshore vehicles and opaque trusts that make it difficult to identify beneficial owners and controllers.
- Concentrations of revenues from high‑risk jurisdictions or sectors, without a commensurate level of documented risk assessment, enhanced due diligence or transaction monitoring.
In online gambling, sudden large inflows from non‑transparent wallets or exchanges, combined with limited customer profiling and weak ongoing monitoring, can also indicate that a platform is being used as a conduit between virtual asset markets and the traditional banking system.
Global risk factors and regional context
Cross‑border activity can significantly heighten exposure. Customers transacting from jurisdictions identified by the Financial Action Task Force (FATF) or national authorities as higher risk for money laundering should warrant additional scrutiny and, where necessary, risk mitigation or even refusal. In e‑gambling, the use of virtual private networks and proxy services can obscure the true location of players, making robust device intelligence and geolocation controls increasingly important.
Regional context also matters. In Southeast Asia, for example, rapid growth in online gambling and associated scam industries has been documented since the mid‑2010s, with links to transnational money laundering networks that move proceeds across multiple countries. Similar patterns of convergence between gambling, cyber‑enabled fraud and human trafficking are increasingly recognised as a structural challenge for regulators and law‑enforcement agencies globally.
White‑label models and recent enforcement in the UK and the Isle of Man
Many online gambling brands operate under white‑label arrangements, where a licensed platform provider offers a turnkey website, technology and regulatory umbrella to third‑party brands. Many of these licences have historically been obtained in jurisdictions such as Malta and the Isle of Man, which positioned themselves as attractive for gambling operators thanks to streamlined licensing and lower tax regimes. The white‑label model allows brands to reach international customers efficiently, but it also creates a dependency on the platform provider’s due diligence and monitoring of its partners.
Recent regulatory actions involving TGP Europe Limited (‘TGP Europe’) and Celton Manx Limited (‘Celton Manx’) illustrate these vulnerabilities. Both companies were incorporated in the Isle of Man, but they played different roles in relation to SBOTOP, an Asia‑facing online sports betting and casino brand. Celton Manx owned and operated the SBOTOP betting brand, while TGP Europe acted as the UK‑facing white‑label operator, holding the UKGC licence and providing the technical platform through which SBOTOP and other Asia‑facing brands could offer services in the UK. TGP Europe surrendered its GB licence in May 2025 after the UKGC had determined that it should pay a GBP 3.3 million penalty package and implement significant improvements if it wished to continue trading, following findings of anti‑money‑laundering failings, including insufficient checks on business partners, weaknesses in due diligence and a failure to consider whether third‑party activity might be illegal in relevant markets. For example, one of the betting platform which enjoyed TGP Europe’s white-label network, was BJ88, an online betting platform headquartered in the Philippines and primarily targeting customers in Asian markets. In a related development, the Isle of Man Gambling Supervision Commission imposed a discretionary civil penalty of GBP 3.9 million on Celton Manx in a decision published in July 2025, after finding systemic shortcomings in risk assessment, customer due diligence, ongoing monitoring and the governance of partner relationships.
These cases do not establish that the brands or their partners were themselves engaged in criminal conduct. Instead, they underscore how gaps in oversight of white‑label networks can expose licensed entities to heightened financial crime risk and regulatory action. They also demonstrate that regulatory expectations increasingly extend beyond core operators to the broader ecosystems of sponsors, intermediaries and associated businesses.
Southeast Asian organised crime and European exposure
Organised crime groups linked to gambling in Southeast Asia often operate large unlicensed and grey‑market online betting platforms, particularly targeting customers in mainland China, where gambling is generally prohibited outside state‑controlled lotteries and tightly regulated venues. To circumvent restrictions, these actors have established hubs in locations with historically limited oversight, including parts of Cambodia, Laos, Myanmar and the Philippines, sometimes within special economic zones and casino clusters. These hubs have been associated with an increasingly tight interlinkage between illegal online gambling, underground banking, virtual‑asset‑based money laundering and, in some reported cases, human trafficking into scam and gambling compounds.
These operations generate revenue through traditional house margins on high volumes of bets, credit betting arrangements, commission‑based agent networks and, in some instances, manipulated games or sports events, alongside large‑scale online fraud schemes run from the same compounds. The exploitation of trafficked labour in scam and gambling operations is itself a profit centre, reducing costs while enabling around‑the‑clock fraud and betting activity. The same infrastructure is then used to move funds across borders through payment processors, informal value transfer systems, shell companies, and bank accounts in tightly regulated jurisdictions, blending illicit proceeds with apparently legitimate gambling revenue.
For Europe, the implications include exposure to suspicious betting patterns, potential match‑fixing risks, inbound flows from high‑risk platforms and the use of payment service providers and sponsorship arrangements that may be linked, directly or indirectly, to this broader ecosystem. The SBOTOP enforcement outcomes highlight how these dynamics can intersect with European sports and regulated gambling markets. Regulators have emphasised that operators and their partners must demonstrate meaningful scrutiny of cross‑border relationships, including a clear understanding of where activity is conducted, who ultimately owns and controls the brands involved, and how funds flow through the network.
Premier League clubs in the regulatory spotlight
In the UK, these issues have attracted particular public attention because several Premier League football clubs had been sponsored by betting brands operating under TGP Europe’s white‑label licence. During the 2024/25 season, for example, AFC Bournemouth and Fulham FC had front‑of‑shirt sponsors BJ88 and SBOTOP respectively, alongside other TGP Europe‑linked brands at Wolverhampton Wanderers, Burnley and Newcastle United. Following TGP Europe’s surrender of its UK licence in May 2025, the UKGC wrote to the clubs to warn that club officers could face prosecution, fines or imprisonment if they continued to promote unlicensed gambling businesses that transact with UK consumers, and reminded them that they must conduct sufficient due diligence on sponsors and ensure that their own marketing and digital channels do not direct fans to, or promote, unlicensed gambling sites. This marked an important shift in expectations, signalling that regulators now look for robust compliance not only from gambling operators themselves, but also from sports organisations and other partners that help bring betting brands to market. Separately, Premier League clubs had already agreed to remove front‑of‑shirt gambling sponsorship from the start of the 2026/27 season, with existing deals permitted to run until the end of the 2025/26 season.
Key takeaways for gambling operators and their partners
Several practical lessons emerge for gambling operators, financial institutions and sports organisations engaging with the gambling sector:
- Prioritise detection of behavioural red flags: unusual customer, transaction or partner patterns should trigger timely review and, where necessary, escalation.
- Follow the money: source of funds and source of wealth must be plausible, evidenced and documented; when they are not, the appropriate response is to slow the process, seek clarification and, if unresolved, decline the relationship or transaction.
- Embed regional and sector context: risk assessment should reflect local law, cultural practices, and enforcement intensity, recognising that risk patterns in, for example, Southeast Asian online gambling may differ from those in mature European markets, but can still create cross‑border exposure.
- Use enhanced due diligence proportionately: for higher‑risk relationships, including those involving complex structures, large values, offshore elements or high‑risk jurisdictions, enhanced checks should be substantive, analytical and ongoing, not merely a checklist exercise.
Ultimately, sustained trust in the gambling sector will hinge on operators and their partners demonstrating that they understand their specific risk profile, invest in appropriate controls, and respond constructively when regulators and law‑enforcement agencies identify weaknesses. In an environment of intensifying scrutiny, richer data and tougher cross‑border enforcement, those who treat financial crime risk as a strategic priority, rather than a box‑ticking exercise, will remain credible counterparties.
