The British Home Office has declared that there has been an increase in illegal casinos targeting the UK in its latest National Risk Assessment (NRA).
Citing this and other factors the Home Office has raised the anti-money laundering (AML) from low to medium, though the risk for terrorist financing remains low.
The risk level was maintained at low in the 2017 and 2020 Home Office’s NRAs, but the department has opted to raise it due to a number of changes it has observed over the past five years.
Changes in customer, geographical and transaction risks are the main reasons cited by the Home Office. The government is particularly concerned with the increase in funds moving through online casinos, new ways to play casino games and an updated assessment of casinos as Money Service Businesses (MSBs).
In this latter case, not all casinos function as MSBs and the Home Office has noted that the number of casinos offering services like foreign currency exchanges and cheque cashing services has declined, some still do.
MSB services heighten the money laundering risk faced by UK casinos, the Home Office asserts. The 2025 NRA stresses that MSB services attract higher risk customers using higher risk transactional methods, such as those making transitions to and from high risk jurisdictions.
White labels under spotlight
The connectivity between the UK casino sector and counterpart industries in more high risk financial jurisdictions has been causing a headache for British authorities, and those of other jurisdictions, for some time.
Even more alarming for the government is the alleged connections between some UK casino companies and illegal overseas operations. White label deals have been cited as being of particular concern here.
White label deals are commonplace in the UK, whereby companies pay a white label partner to operate their UK domain for them under said partners’ licence. The Home Office is concerned about some cases where operators have relied on unlicensed third parties for compliance.
“In these cases, the licensee would remain responsible for compliance, although they did not always have sufficient oversight,” the National Risk Assessment details.
“These arrangements are now less common, but risks remain where white-label providers offer large numbers of websites, as failure by a single remote casino to control the ML risks relating to their white-label partnerships can impact a significant number of websites.”
White label deals have been the subject of some negative press over the past couple of years. Much of this publicity has been around Isle of Man-based companies, with TGP Europe in particular getting a lot of attention.
Last year, the licence for TGP Europe-operated Kaiyun Sports expired, leading the UK Gambling Commission (UKGC) warning the company’s then football partners, Nottingham Forest and Crystal Palace, to reconsider the sponsorships.
TGP Europe would later shut down all of its brands in April 2025, surrender its operating licence and have to pay a substantial fine to the Commission, which accused the firm of failing to carry out sufficient due diligence against its partners, among other licensing breaches.
This came after years of mourning concerns at the Isle of Man government around the island’s targeting by international criminal groups. The Crown Dependency’s government shared concerns previously raised by the UN about the extensive activity of East Asian and Southeast Asian illegal gambling and cryptocurrency operations.
The UK Home Office risk assessment has not singled out any particular geographic region. However, the Home Office has noted that Suspicious Activity Reports (SARs) around illegal activity related to casinos have increased from 2020, rising from 6,000 in 2022/23 to 7,500 in 2023/24.
“Illegal casinos continue to attract new customers, heavily targeting online advertising with offers that entice new customers to gamble with them,” the NRA read.
“As they operate illegally, they will not be supervised by the Gambling Commission, nor have a requirement to implement MLR controls. The use of cryptoassets in illegal casinos is also increasing.”
Illegal casinos have been met with regulatory and enforcement action. The report notes that the UKGC issued 1,158 stage one cease and desist notices relating to online casinos, referred 118,181 URLs to Google and Bing and had 81,292 URLs promoting casinos from search engine results between April 2024 and March 2025, for example.
Further challenges are on the horizon though, particularly technological ones. The NRA highlights the use of AI as a key example, with deepfaked documentation commonly used to bypass compliance checks.
The Home Office has also cited the use of in-game currencies as presenting fraud and money laundering risks and crash games being offered by some licensed casinos as presenting a money laundering opportunity for criminals.
The timing of this report is apt, coming at the same time that the licensed betting industry both in the UK and in other European nations continues to make the case that a gambling black market is posing significant risks to regulated gambling sectors.
However, while the NRA has noted the increase in prevalence of illegal gaming, something licensed operators have been highlighting for years, it does also point out some flaws in the regulated industry that operators may want to address if they want their black market concerns to be taken seriously.
