Gambling Commission raises software sector’s laundering risk

• The Gambling Commission’s 2026 risk assessment moves gambling software from low to medium risk, citing weak due diligence on B2B customers, investors and resale contracts.
• Cryptoasset transactions linked to software businesses are newly listed as a high-risk vulnerability, alongside B2B partners based in high-risk jurisdictions.
• The assessment lands one week after a £4.75 million settlement with Evolution Malta Holding Limited, whose games reached unlicensed websites through a business partner.

The Gambling Commission has moved the gambling software sector’s money laundering risk rating from low to medium in its 2026 risk assessment, published on 30 July and covering licensed activity from 1 April 2023 to 31 October 2025.

The report names specific gaps in how software suppliers vet the businesses they sell to, invest alongside and get resold through.

Where the risk sits now

Two vulnerabilities in the software sector’s risk table carry an increased rating. Due diligence on B2B customers, including test houses, shows an increase in both impact and likelihood. Insufficient monitoring of third-party contracts, which lets licensed games get resold onto unlicensed sites without the original supplier’s knowledge, appears for the first time as its own listed risk.

Cryptoasset transactions tied to software businesses, whether received directly or channelled through an investor, are also newly listed as a high-risk vulnerability. So is having a B2B partner based in or linked to a high-risk jurisdiction. Due diligence on business investors has increased too, with the Commission citing cases involving Initial Coin Offerings where source-of-funds checks on token buyers were never completed.

None of this touches player-facing controls. It concerns who a supplier does business with, and how well that relationship is checked before and after a contract is signed.

Evolution sets a marker

The Commission is already enforcing against these gaps ahead of the new assessment.

One week earlier, on 23 July, Evolution agreed to pay £4.75 million after its games appeared on six unlicensed sites reaching British consumers.

Evolution holds both a gambling software licence and a casino game host licence, and its settlement followed a risk assessment that failed to flag two business partners reselling its games without a Commission licence.

John Pierce, the Commission’s Director of Enforcement, said:

“This case exposed serious weaknesses in Evolution’s anti-money laundering risk assessment and its oversight of risks within its supply chain.”

Pierce added that operators “need to understand who they are supplying their games to, how and where those games are being accessed in practice,” backed by ongoing controls.

What software licensees should check

Three areas carry the most immediate exposure. Reseller and distributor contracts need active monitoring for where software actually ends up, not just where the agreement says it will.

Investor and B2B customer onboarding needs source-of-funds checks robust enough to catch what the ICO-funded applicant in the Commission’s case studies missed. Crypto-funded relationships, whether investment or payment, warrant enhanced scrutiny rather than standard treatment.

The same assessment notes that HM Government has allocated £26 million over three years for the Commission to pursue illegal gambling markets directly, separate from its supervision of licensed suppliers.

For software licensees, the two strands point the same way: a contract that looks clean on paper is not enough if the Commission can show the counterparty knew, or should have known, where the product was going.