FATF: AML red flags in online gambling and gaming. Money laundering risks 

In September 2026 the Financial Action Task Force (FATF), the inter-governmental body that sets global anti-money laundering standards, published its report Risks of Gaming and Gambling with a detailed set of red flag indicators. Drawing on responses from 80 jurisdictions, it is the first broad update since the casino study of 2009. It matters not only to casinos and bookmakers, but also to banks, payment institutions and crypto-asset service providers handling gambling flows.

Key FATF Findings on AML in the Gambling Industry

• land-based and online casinos and sports betting remain the most exposed to money laundering, while some jurisdictions treat lotteries and scratch cards as lower risk;
• laundering through video games happens on a smaller scale, yet FATF records more documented terrorist financing misuse in gaming than in gambling;
• illegal offshore gambling rivals or exceeds the legal market in some countries;
• the indicators fall into five groups: customer profile, online accounts, betting patterns, payment methods and product or platform features.

Who is affected by AML risks in the gambling and payments sectors?

• gambling and betting operators, which Polish law already treats as obliged entities;
• banks, payment institutions and e-money institutions processing player deposits and merchant settlement;
• crypto-asset service providers, e-wallet issuers and prepaid card providers.

How can AML procedures be aligned with FATF guidelines?

• Refresh your business-wide risk assessment. Add the drivers FATF highlights: non-face-to-face onboarding, mixed payment rails, customers linked to unlicensed operators, ownership reaching into high-risk jurisdictions.
• Convert the red flags into monitoring scenarios. Deposits followed by immediate withdrawal with little or no play, several players sharing one IP address or device, withdrawals to an account other than the funding source, pooled deposits from many people ending in a single payout, winnings collected just below an identification threshold.
• Screen your merchant book for sham merchants. FATF describes illicit operators disguising gambling payments as ordinary retail activity, so review merchant category codes and actual volumes.
• Review partner arrangements. White-label deals, agents and introducers, and contracts for intangible services that lack clear commercial logic.

Penalties for AML violations and failure to address risks identified by the FATF

The report does not change the law, but it sets the benchmark supervisors use. The Polish General Inspector of Financial Information (GIIF) and the Polish Financial Supervision Authority (KNF) ask whether an institution has recognised the risks described in current international guidance. Weak risk assessments and thin monitoring expose the company to substantial administrative fines and the designated senior manager to a personal penalty.

AML in the Gambling Industry: Prepare for New Risks Identified by the FATF

AML in the gambling sector today requires addressing new and increasingly complex risks related to payments, online gaming, and the flow of funds. It’s worth checking whether your risk assessment, AML procedures, and transaction monitoring system take into account the red flags identified by the FATF and meet the current expectations of regulatory authorities.

If you serve gaming operators, provide payment services to the gambling sector, or work with entities involved in cryptoassets, we can help you translate the FATF’s guidance into specific monitoring scenarios and compliance solutions. For more information on Polish AML obligations, see our guide “Anti-Money Laundering Regulations in Poland.” Contact us to discuss the AML risks associated with your business and determine what steps you should take.