The Gambling Commission has raised concerns about AI-related threats to the customer due diligence process in its updated 2025 guidance on emerging AML risks.
The UK regulator noted a growing trend in the use of AI-generated documents, deepfake videos, and face swaps to circumvent identity checks.
A recent report from the National Crime Agency also warned that AI-created accounts are increasingly linked to criminal activities such as money laundering and terrorist financing.
As a result, the Commission emphasized that gambling operators must ensure their staff are properly trained to detect and assess AI-generated fraudulent documents.
A blog post by gaming lawyers at Wiggin LLP stressed the importance for all operators to carefully consider this information and be able to show evidence of it to the Commission. This involves conducting a thorough, documented evaluation of the risks involved, assessing their relevance to the business, outlining mitigation strategies, and clearly integrating these into internal policies and procedures.
The firm also noted that the Commission has previously criticized operators for not documenting why a specific emerging risk was deemed irrelevant to their operations.
The regulator also flagged crash games as a potential money laundering risk. Although these games are not licensed in the UK, they are commonly found on offshore crypto casinos and have seen a surge in popularity in recent months.
The Commission expressed concern that such games may enable criminals to mask high-risk behavior, such as rapid cash-outs with minimal gameplay, since these actions are typical within the crash game format. This could make it harder for transactional monitoring systems to identify suspicious activity.
Another emerging AML risk identified by the UK Gambling Commission is the increased presence of money service business (MSB) activity at both land-based and online casinos. This involves scenarios where casinos accept large denomination notes in foreign currencies, which can present a money laundering threat.
While the number of casinos providing this service has decreased, the regulator noted that it still occurs and has therefore categorized it as a high-risk activity in its latest assessment.
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