Anti-Money Laundering in Gambling: FATF, the EU AML Package and AMLA

Gambling businesses handle large volumes of cash and digital payments, and can turn stakes into “winnings” that look legitimate. That makes them attractive to criminals, so anti-money laundering (AML) and counter-terrorist financing rules apply to gambling almost everywhere it is regulated. This explainer covers the global standards, the EU’s new regime and what AML means in practice for operators and players, as of October 2026.

How gambling is used to launder money

The classic methods include:

• Cash-in, cash-out: buying chips or depositing funds, playing minimally, then withdrawing “clean” winnings
• Chip dumping and collusion: deliberately losing to an accomplice at poker or on betting exchanges
• Account and identity misuse: using money mules, stolen identities or third-party payment methods
• Buying winning tickets: paying a premium for a genuine winning lottery or betting slip
• Spending criminal proceeds: gambling with stolen or fraudulently obtained money, which is the most common real-world case in operators’ enforcement histories

The global standard: FATF

The Financial Action Task Force (FATF) sets the international AML standards that more than 200 jurisdictions have committed to. Under its Recommendations:

• Casinos are designated non-financial businesses and professions (DNFBPs). They must carry out customer due diligence for transactions at or above USD/EUR 3,000, keep records and report suspicious transactions.
• Countries must license casinos and subject them to effective AML supervision.
• FATF’s mutual evaluations assess how well each country implements the standards. Weak results can lead to “grey list” status, with real economic consequences.

Many countries go further than FATF requires, applying AML rules to all online gambling and betting, and setting lower thresholds.

The EU’s AML package

The EU adopted a major reform in 2024:

Instrument	What it does	Key date
Anti-Money Laundering Regulation (EU) 2024/1624 (AMLR)	A single, directly applicable rulebook for obliged entities, including gambling providers	Applies from 10 July 2027
AMLA Regulation (EU) 2024/1620	Creates the Anti-Money Laundering Authority, based in Frankfurt	Applied from 1 July 2025
Sixth AML Directive (EU) 2024/1640	National supervisors, financial intelligence units and beneficial ownership registers	Transposition mostly by July 2027

What changes for gambling

• Due diligence threshold: under the AMLR, gambling providers must apply customer due diligence on collecting winnings, wagering a stake, or both, when transactions reach €2,000, whether in a single operation or several that appear linked. They must also apply it whenever they establish a business relationship, such as opening an online account.
• Limited exemptions: member states may exempt some lower-risk gambling, such as certain lotteries, but not casinos, online gambling by private operators or betting.
• Harmonised rules on beneficial ownership, politically exposed persons and record-keeping replace differing national transpositions.
• Cash cap: the AMLR introduces an EU-wide €10,000 limit on large cash payments for goods and services, with member states free to set lower limits.

AMLA’s role

AMLA will directly supervise a limited group of high-risk, cross-border financial institutions. For non-financial sectors, including gambling, it coordinates national supervisors, issues guidance and technical standards, and can carry out peer reviews. Day-to-day supervision of operators remains with national regulators, such as the gambling authorities in Malta, Sweden or Germany, or, in some countries, financial supervisors.

Outside the EU

• United Kingdom: casinos, including online casinos, are covered by the Money Laundering Regulations 2017. All Gambling Commission licensees must comply with the Proceeds of Crime Act 2002 and licence conditions on AML. Many large UK fines have involved AML and social responsibility failures.
• United States: casinos and card clubs are “financial institutions” under the Bank Secrecy Act, with currency transaction reports above $10,000 and suspicious activity reporting. State regulators add their own requirements.
• Curaçao and other hubs: licensing reforms have been driven partly by pressure to meet FATF expectations.

Typical red flags

Compliance teams look for patterns such as deposits followed by withdrawals with little play, frequent changes of payment method, third-party cards, spending far above declared income, and accounts linked by device or address.

What operators must do in practice

1. Risk assessment of the business, its customers, products, payment methods and countries
2. Customer due diligence: identity verification, plus enhanced checks for higher risk, including source of funds and source of wealth
3. Ongoing monitoring of transactions and behaviour, increasingly automated
4. Suspicious activity reporting to the national financial intelligence unit, without tipping off the customer
5. Record-keeping, typically for five years
6. Training and governance, including a nominated money laundering reporting officer

These duties overlap with player protection. A customer spending far beyond apparent means may be a laundering risk, a gambling-harm risk, or both. See affordability and financial risk checks.

Crypto and new payment methods

Crypto-asset service providers are now regulated under the EU’s MiCA framework and the recast Transfer of Funds Regulation, which applies the “travel rule” to crypto transfers from 30 December 2024. Licensed operators in most regulated markets cannot accept crypto. Unlicensed crypto casinos, which often do minimal or no checks, are a major AML concern. See crypto gambling risks.

For players

Expect identity checks at sign-up and further questions if your spending rises or changes. You may be asked for payslips, bank statements or other evidence. Our guide to KYC and identity checks explains what is normal and how to protect your data. For compliance professionals, the compliance function in iGaming covers the operational side. This article is general information, not legal advice.