Ireland raises gambling risk ratings in AML plan

• Ireland publishes a national risk assessment on money laundering alongside a 30-point financial crime action plan on 18 June.
• Remote bookmakers and private members’ clubs receive the two highest money laundering risk scores in the new assessment.
• GRAI is tasked with establishing crypto due diligence standards, and operators will be required to introduce closed-loop bank account payment systems.

The Irish government has published a new National Risk Assessment on money laundering, terrorist financing and proliferation financing, alongside a 30-point action plan introducing new anti-money laundering requirements for the gambling sector.

The plan was launched on 18 June by Tánaiste and Minister for Finance Simon Harris alongside Minister for Justice Jim O’Callaghan.

Elevated risk ratings

The assessment marks a significant upgrade on the previous national risk framework from 2018/19, which rated gambling across categories at medium risk at best, with some not fully assessed.

According to the national risk assessment, remote bookmakers now carry a “significant” risk of money laundering, one of the two highest ratings on the scale. The government pointed to the remote nature of those services, the use of pre-paid cards to fund accounts, and a fragmented EU regulatory landscape as the primary concerns.

White-label arrangements were also flagged in the assessment as a vulnerability, due to the risk of market entry by entities removed from established European standards.

Private members’ clubs (PMCs) received the same “significant” money laundering rating. These are membership-only venues that offer casino-style live games such as poker and slot machines. PMCs have historically fallen outside the scope of the Gaming and Lotteries Act 1956. Under the action plan, they will be subject to mandatory licensing for the first time, bringing them into line with the rest of the regulated sector.

The overall national risk assessment found Ireland faces a moderate threat of money laundering and a low threat of terrorist financing.

Harris said:

“Financial crime is not a victimless crime. Behind every fraud, scam and money laundering operation there are real victims: older people losing their savings, families being defrauded and communities harmed by criminal activity.

“Criminals are becoming increasingly sophisticated, exploiting technology, operating across borders and adapting rapidly to change. Government cannot stand still in the face of these threats.”

Crypto and payment measures

The action plan targets two specific vulnerabilities in online gambling: cryptocurrency and digital payment flows. The Gambling Regulatory Authority of Ireland (GRAI) is tasked with establishing an industry standard for due diligence on crypto-related activities as a source of betting funds, to ensure that money deposited into gambling accounts originates from legitimate sources. That standard is slated for delivery in Q2 2027.

Operators will also be required to introduce closed-loop payment systems, returning gambling payouts to the same bank account used to make deposits. The measure is designed to close a common route for laundering funds through online platforms.

Enforcement will rely on broader inter-agency cooperation. A dedicated national group comprising An Garda Síochána, the Central Bank, Revenue and the Defence Forces is being established to coordinate efforts against terrorist financing and sanctions evasion. The plan also gives AML supervisors new powers to impose fines on agencies and companies that breach the rules.

O’Callaghan said:

“The government will continue to monitor emerging risks and update its response as necessary to ensure Ireland remains resilient in the face of a rapidly evolving threat environment.”

GRAI consolidates control

The action plan builds on a broader regulatory transition already under way. GRAI, which began issuing gambling licences in February 2026 following Minister O’Callaghan’s commencement order, is set to become the sole competent authority for all gambling categories in Ireland, replacing a fragmented patchwork of supervisors. That consolidation is progressing through public consultation and draft regulations pursuant to the Gambling Regulation Act 2024.

The remote licensing deadline is 1 July 2026, with operators already adjusting their Irish footprint. Betfred recently announced a temporary operational pause ahead of that deadline, clearly showing the compliance pressures the transition is generating.

For operators in or entering the Irish market, the action plan adds a further layer on top of licensing obligations. New requirements around crypto due diligence, closed-loop payment architecture and tighter scrutiny of white-label arrangements will shape operators Irish operations, particularly as GRAI moves towards taking on full enforcement powers.