John Pierce, Director of Enforcement at the Gambling Commission, delivered a speech at the Gambling Anti-Money Laundering Group (GAMLG) Annual Conference outlining the regulator's current enforcement priorities, upcoming publications and broader policy developments.
Pierce acknowledged overall improvement in industry compliance but warned that significant failings remain.
Chief among these is a recurring disconnect between operators' written AML policies and their practical application on the ground – a concern he described as persistent and one that senior executives have at times been unaware of within their own businesses.
"If you take anything away from this speech today," he said, "make sure you go back to your businesses and make sure your application and practice matches the outcomes of your risk assessments and what your policies say should be happening."
Other issues identified in casework include Personal Management Licence (PML) holders failing to exercise sufficient oversight of AML controls; operators not taking a risk-based approach to internal assessments; inadequate employee training leading to missed red flags in documents such as bank statements; insufficient due diligence on third-party relationships; poor record-keeping; and over-reliance on financial thresholds without adequate prior customer risk profiling.
Pierce also cautioned that AI and algorithmic tools used for AML purposes are, in many cases, not yet delivering the required compliance outcomes.
On upcoming publications, Pierce confirmed that an updated money laundering and terrorist financing risk assessment is expected in July, with an emerging risks bulletin to follow in the Autumn.
Regarding crypto, he signalled that the Commission is exploring a regulatory path for cryptoassets as a consumer payment option, describing it as potentially "a strength of our AML infrastructure, as opposed to a weakness."
This speech follows recent Commission activity on several fronts. In May, Director of Policy Ian Angus addressed the Clarion Payment Providers Summit, covering illegal gambling, FRAs and crypto, while the Commission also confirmed it would delay the rollout of financial risk assessments as it continues to assess the evidence base.
The Gambling Commission reported issuing 741 cease-and-desist notices and disrupting 1,134 illegal gambling websites over the past year as part of its efforts to combat the black market