Casino and Gambling Clients: AML Changes for Accountants

Casinos are one of the sectors the Money Laundering Regulations 2017 single out for their own anti-money laundering rules, and the Gambling Commission supervises them. If your accountancy firm acts for a casino operator, a casino supplier, or a group with a gambling arm, you need to understand two things: what changed for casinos on 30 June 2026, and how a client in a regulated, cash-heavy and high-scrutiny sector should be treated at acceptance and during the engagement. This guide covers both. It builds on our guide to client risk rating, acceptance and exit.

What changed for casinos from 30 June 2026

The Gambling Commission's notice on the upcoming changes says Parliament approved the amending statutory instrument on 9 June 2026, with most changes taking effect on 30 June 2026. For casinos, the Commission highlights these points:

• Sterling thresholds. References to euros in the regulations become sterling. The Commission's example is the customer due diligence trigger in regulation 27, which moves from 2,000 euros to £2,000. The amendment regulations (SI 2026/621) confirm this change to regulation 27(5).
• High-risk countries. Under regulation 33, a casino must apply enhanced due diligence where a transaction or relationship involves a person established in a country on the FATF "Call for Action" list, but no longer automatically for countries on the "Increased Monitoring" list. Geographic risk must still be considered under regulation 33(6)(c), and both FATF lists are updated three times a year after plenary meetings.
• Complex transactions. Enhanced due diligence now applies to "unusually" complex transactions rather than all complex ones. The rule for unusually large transactions is unchanged. The Commission reminds casinos they must still consider wider geographic, product and customer risk factors.

The Commission expects operators to update their money laundering and terrorist financing risk assessment, then their policies, procedures and controls. It has said it will update its casino guidance after the changes take effect, including guidance on when a business relationship is established.

Why this matters to the casino's accountant

You do not need to run the casino's compliance programme, but your engagement touches it in several places. The operator's own risk assessment and controls affect the numbers you audit or report on, the provisions and costs you review, and the regulatory risks your client faces. A casino that has not updated its policies after 30 June 2026 is exposed to supervisory action, and that can show up in your work as a going-concern, disclosure or governance question.

It also affects how you treat the client. A casino operator is a regulated business with a licensing regime, so it is not automatically high risk, but the sector deals in large cash and electronic flows, and its customers may include politically exposed persons and people connected to higher-risk countries. Apply the same structured approach you use elsewhere, as set out in our KYC checklist for onboarding a new client.

Client acceptance checks for a gambling client

• Licensing. Confirm which licences the business holds and with whom, and check the licensing position directly with the regulator rather than relying on the client's description.
• Ownership and control. Establish who owns and controls the business, including any offshore holding structure, and verify beneficial owners as you would for any client.
• Source of funds. Understand how the business is financed and how profits move up the group.
• Compliance function. Ask who the money laundering reporting officer is, when the risk assessment was last reviewed, and whether it was updated for the 2026 amendments.
• Adverse information. Search for regulatory sanctions, licence reviews and enforcement action involving the business or its senior managers.

Record your reasoning. If the information is incomplete or the client will not explain structures or funding, treat that as a red flag and decide whether to proceed. Our practical guide to money laundering red flags for accountants shows how to escalate concerns.

During the engagement

Ask for the operator's latest risk assessment and any regulator correspondence as part of your normal planning. Look for movements that do not match the business model, such as unexplained third-party payments, loans from related parties with no commercial rationale, or income that does not reconcile to player activity data. These are not casino-specific tests but ordinary professional scepticism applied to a sector where money-laundering risk is recognised in legislation.

If you form a suspicion that the client's funds, or a transaction you see, relate to criminal property, report it internally under your firm's procedure so your nominated officer can consider a report to the National Crime Agency. Do not discuss the concern with the client in a way that could tip them off.

Keeping up to date

The Commission has said it will review its casino AML guidance, so expect further changes in the coming months. Subscribe to its updates, and add a line to your own risk assessment recording the date you reviewed the 2026 changes. For team training on these topics, see Learnsignal's CPD courses for finance professionals.

Frequently asked questions

Is a casino client automatically high risk?

No. Risk depends on the structure, ownership, countries involved and your own assessment. The sector is regulated for money laundering, so expect higher scrutiny of the client's controls, and record your conclusion.

What is the new customer due diligence trigger for casinos?

The Gambling Commission says the regulation 27 trigger that was 2,000 euros is now £2,000, with most of the changes taking effect on 30 June 2026. Check its casino guidance for how this applies in practice.

Do the changes apply to my own firm?

The casino-specific points do not, but the changes to enhanced due diligence for high-risk countries and unusually complex transactions apply across the regulations.