FATF Report 2026: Money Laundering in Gambling and Online Gaming
In its latest report, “Risks of Gaming and Gambling”, published on 9 September 2026, the Financial Action Task Force (FATF) warns of growing money laundering and terrorist financing risks in the gambling and gaming sector. Online casinos, sports betting, cryptocurrencies, digital payment service providers and illegal gambling platforms are at the centre of the analysis. For money laundering reporting officers, the report provides important insights for risk assessments, transaction monitoring and the identification of suspicious business relationships.
FATF examines new money laundering risks in the gambling sector
The gambling industry has changed fundamentally in recent years. While traditional casinos and land-based betting shops have long been regarded as relevant to money laundering, digital business models create additional risks.
Online casinos, sports betting operators and gaming platforms enable cross-border payments, the use of different payment methods and the transfer of assets between various parties.
The FATF examined these developments in its report “Risks of Gaming and Gambling – Red Flag Risk Indicators”.
The analysis is based, among other things, on questionnaire responses from 80 jurisdictions, written submissions from 29 jurisdictions, and consultations with industry representatives and other experts.
The report focuses in particular on:
- Land-based casinos and online casinos
- Sports betting and other betting services
- Lotteries, gaming machines and other forms of gambling
- Online video games and mobile gaming platforms
- Illegal and unlicensed gambling operators
- Payment service providers, e-wallets and virtual assets
- Links between gambling platforms and social networks
The key finding is that gambling and online gaming are increasingly part of an international, digitally interconnected payments ecosystem. This creates additional opportunities for money laundering, terrorist financing and the concealment of beneficial ownership.
1. Online casinos and sports betting are particularly vulnerable to money laundering
According to the FATF’s findings, land-based casinos, online casinos and sports betting are among the areas of the gambling sector particularly exposed to money laundering.
The risks vary considerably depending on the business model, payment channel and structure of the gambling offering.
A significant money laundering risk arises where funds are deposited into gambling accounts and subsequently withdrawn as purported winnings or account balances.
Examples of suspicious patterns include:
- High deposits with little or no actual gaming activity
- Withdrawals to accounts other than those originally used for deposits
- The use of numerous different payment methods
- Suspicious betting patterns involving little risk of loss
- Coordinated betting between several players
- Unusually high or frequent withdrawals
So-called non-genuine play patterns are particularly relevant: players deposit substantial amounts but actually stake only comparatively small sums before withdrawing the remaining balance.
For money laundering reporting officers, the transaction volume alone is therefore not decisive. The relationship between deposits, actual gaming activity and withdrawals is particularly important.
2. Cryptocurrencies, e-wallets and third-party payments increase the risks
The FATF also focuses on the growing variety of payment methods.
In addition to cash, credit cards and conventional bank transfers, gambling operators may use:
- Cryptocurrencies and other virtual assets
- Electronic wallets (e-wallets)
- Mobile payment services
- Prepaid cards and vouchers
- Payment intermediaries and international payment service providers
The combination of these payment instruments can make it more difficult to trace the flow of funds.
Transactions in which several depositors transfer funds to a gambling account and a subsequent withdrawal is made to a single beneficiary are particularly suspicious.
The use of different accounts, payment service providers and cryptocurrencies may also indicate an increased money laundering risk.
The FATF expressly identifies third-party deposits, the splitting of deposits into smaller amounts and the consolidation of different sources of funds as relevant risk indicators.
Implication for transaction monitoring: Where relevant business relationships are concerned, credit institutions and payment service providers should not examine individual transfers in isolation. They should also analyse payment flows across multiple accounts, payment methods and beneficiaries.
3. Illegal gambling platforms as a significant risk factor
The FATF pays particular attention to illegal and unlicensed gambling operators.
According to the FATF’s findings, in some countries the illegal gambling market is as large as, or even larger than, the legal market.
Illegal operators may create significant money laundering risks through cross-border business models, a lack of customer due diligence obligations and opaque corporate structures.
Complex ownership structures can further complicate the identification of the individuals who ultimately exercise control.
A particularly relevant risk indicator is the concealment of the true purpose of payments through so-called “sham merchants”.
In such cases, gambling transactions are processed through apparently ordinary trading businesses, meaning that the relevant payments may appear in the payment system to be standard retail transactions.
This can create significant risks for banks, payment service providers and acquirers.
Money laundering reporting officers should therefore scrutinise the actual economic activity and the plausibility of transaction structures, particularly where unusual payment service providers, online merchants and gambling companies are involved.
4. Online gaming: new terrorist financing risks
The FATF expressly distinguishes between traditional gambling (gambling) and digital video games or online gaming (gaming).
Based on the available findings, money laundering through gaming services currently appears to occur on a smaller scale and with less documented frequency and complexity than money laundering through traditional gambling services.
The situation is different in relation to terrorist financing.
In the online gaming sector, the FATF identifies better-documented opportunities for abuse than in the traditional gambling sector.
Links between gaming platforms, social networks and digital communication services play a particularly important role.
These may be used, among other things, for:
- The dissemination of extremist propaganda
- Contact and recruitment
- The coordination of illegal activities
- Raising funds for terrorist financing
As a result, platform-related risks and the identification of suspicious user structures are becoming increasingly important alongside traditional payment indicators.
At the same time, the FATF notes that the documented risks of proliferation financing in the gaming and gambling sector remain very limited.
5. FATF publishes specific red flags for money laundering reporting officers
A key part of the publication is its compilation of specific risk indicators.
These can be divided into five categories.
Suspicious customer behaviour and customer profile
Relevant warning signs include:
- Inconsistencies in identity and address details
- Refusal to comply with, or attempts to circumvent, customer due diligence measures
- Assets or financial circumstances that do not match the known customer profile
- An unclear or unsubstantiated source of funds
- The use of accounts or payment instruments belonging to other people
- Links to high-risk countries or sanctioned persons
Unusual interest in internal control mechanisms, reporting thresholds or statutory reporting obligations may also constitute an additional risk indicator.
Suspicious activity involving online accounts
For online gambling platforms, the FATF highlights in particular:
- Multiple user accounts under different identities using the same IP address or device
- Repeated use of VPN connections to conceal the user’s location
- Discrepancies between the stated place of residence and the technically identified location
- Sudden high deposits into previously inactive accounts
- Suspicious changes in deposit and withdrawal patterns
However, a single technical feature, such as the use of a VPN, does not in itself establish a suspicion of money laundering.
Unusual betting patterns
In sports betting and online casinos, the following behaviours may be particularly relevant:
- Hedging across different possible outcomes
- Coordinated betting by several players
- Repeated losses benefiting specific other players
- Suspicious winning streaks that are difficult to explain
- Large deposits with minimal gaming activity
- Betting on potentially manipulated sporting events
The FATF also identifies so-called peer-to-peer anomalies, such as the deliberate transfer of in-game value to other participants (chip dumping), as risk indicators.
Suspicious payment structures
The FATF identifies, among other things:
- Numerous deposits within short periods
- Deposits made by economically unrelated third parties
- The use of multiple payment methods held by different individuals
- Immediate withdrawals without significant gaming activity
- Transfers from numerous international bank accounts
- Payments to high-risk countries or unusual beneficiaries
The consolidation of numerous small deposits into larger withdrawals to individual persons is particularly relevant.
Suspicious features of gambling operators and platforms
The operators themselves may also present increased risks.
These include:
- Opaque beneficial ownership
- Complex international corporate structures
- Inadequate anti-money laundering controls
- A lack of, or inadequate, oversight of service providers
- Business relationships that lack an economically plausible rationale
- Unusual increases in turnover without a plausible economic explanation
- Frequent changes to company names or website addresses
These indicators are particularly relevant to credit institutions that provide accounts and payment services to gambling companies or payment service providers.
6. What does the FATF report mean for risk assessments under the German AML Act?
For money laundering reporting officers in Germany, the FATF’s findings provide important guidance for developing the organisation-wide risk assessment under section 5 of the German Money Laundering Act (Geldwäschegesetz – GwG).
The report does not itself create any new statutory obligations. However, it contains current international findings that may be taken into account when identifying and assessing relevant money laundering and terrorist financing risks.
In particular, the following questions should be considered:
Business relationship risks: Are there direct or indirect business relationships with gambling companies, online casinos, betting operators or gaming platforms?
Transaction risks: Are unusual payment structures, third-party payments or suspicious deposits and withdrawals being identified adequately?
Country risks: Are there links to countries with increased money laundering risks, inadequate gambling regulation or problematic supervisory structures?
Product risks: Do the payment products offered enable rapid, cross-border or difficult-to-trace transfers of value?
Service provider risks: Are there dependencies on payment intermediaries, white-label providers or other third parties whose economic activities and control systems are not sufficiently transparent?
The assessment should be risk-based and should reflect the actual exposure of the relevant obliged entity.
7. Implications for transaction monitoring and suspicious activity reports
The new FATF risk indicators can serve as a basis for developing existing monitoring scenarios.
For credit institutions and payment service providers, the following review approaches may be particularly relevant:
| Monitoring scenario | Potential risk indicator |
|---|---|
| High deposits followed by prompt returns | Little or no economically plausible gaming activity |
| Many depositors, one withdrawal recipient | Pooling of funds from different sources |
| Payments through numerous third-party providers | Reduced traceability of payment flows |
| Frequently changing payment recipients | Unusual onward transfer of assets |
| Suspicious offshore payment flows | Links to illegal or higher-risk operators |
| Payments to apparently ordinary online merchants | Possible concealment of gambling transactions |
A distinction must be made between the information available to different obliged entities.
While gambling operators can generally examine gaming and account activity within their own platforms, credit institutions often have access only to payment transaction data.
Monitoring must therefore be tailored to the data, products and actual risks available to and faced by the relevant organisation.
Important: The FATF expressly emphasises that a single risk indicator does not automatically indicate money laundering, terrorist financing or proliferation financing.
However, where several suspicious features occur together, a more detailed investigation may be required.
When considering whether to file a suspicious activity report under section 43 of the GwG, the specific circumstances of the individual case and the statutory requirements are decisive. A criminal conviction or proof of a criminal offence is not required in order to submit a suspicious activity report.
8. Five recommendations for money laundering reporting officers
The FATF report gives rise to five practical measures for preventing money laundering.
1. Review the risk assessment
Existing risk assessments should be reviewed to determine whether the organisation may be exposed to online casinos, sports betting, digital gaming platforms and illegal gambling operators.
2. Update customer risk classification
The activities of gambling companies, payment service providers and relevant platform operators should be assessed with regard to their business model, payment channels, licensing status and geographical activities.
3. Expand transaction monitoring on a risk-sensitive basis
Relevant FATF indicators should be compared with existing monitoring scenarios, and appropriate adjustments should be considered where gaps are identified.
4. Investigate suspicious business relationships in greater depth
Unusual third-party payments, complex ownership structures, implausible sources of funds and links to illegal operators should be assessed in light of the information available.
5. Update staff training
Employees working in anti-money laundering, compliance, payments, customer service and relevant control functions should be made aware of the new risks.
Clear documentation of the risk assessment and any measures adopted supports effectiveness testing and supervisory accountability.
FATF Report 2026 provides important insights for preventing money laundering
Through its report “Risks of Gaming and Gambling”, the FATF makes clear that money laundering and terrorist financing risks in the gambling sector increasingly extend to digital business models, international payment structures and interconnected platforms.
The risks associated with online casinos, sports betting, unlicensed gambling operators and the use of cryptocurrencies, e-wallets and third-party payments are particularly relevant.
For money laundering reporting officers, the extensive compilation of specific red flags is especially valuable.
The key task is to translate the FATF’s findings into the organisation-wide risk assessment, customer risk classification, transaction monitoring and internal safeguards on a risk-sensitive basis.
Risks should neither be assumed indiscriminately nor should individual indicators be treated in isolation as proof of a criminal offence.
Instead, the focus should be on a well-documented overall assessment of the business relationship, customer behaviour and relevant payment structures.
Frequently Asked Questions (FAQ)
What money laundering risks exist in online casinos?
The main risks include deposits from unexplained sources, withdrawals despite limited gaming activity, third-party payments and the use of different payment methods. Manipulated gaming activity and opaque operator structures may also be relevant.
Which FATF red flags are particularly important for banks?
For banks, particularly relevant indicators include unusual payment flows to gambling operators, deposits made by numerous third parties, international payment intermediaries, suspicious return transfers and business relationships with unlicensed gambling platforms.
Are cryptocurrencies inherently suspicious in online gambling?
No. The use of virtual assets is not, in itself, evidence of illegal activity. However, the FATF points to potential additional risks arising from difficult-to-trace payment routes, cross-border transactions and the combination of different payment methods.
Do money laundering reporting officers have to update their risk assessments because of the FATF report?
The FATF report itself does not create a separate statutory obligation to update a risk assessment. However, obliged entities must identify and assess their risks in accordance with the applicable legal requirements and review their risk assessments regularly and when circumstances require. Where the FATF’s findings are relevant to the organisation’s business model, they should be taken into account in that assessment.
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Source: https://www\.fatf\-gafi\.org/en/publications/Methodsandtrends/risks\-of\-gaming\-and\-gambling\.html