FATF publishes new red flag indicators for gambling

The watchdog’s first detailed look at online and illegal gambling found unlicensed markets that rival or exceed legal ones in some countries.

The last time the Financial Action Task Force looked closely at gambling, in 2009, the subject was casinos. On 9 September 2026, the inter-governmental watchdog published a much wider study covering online play, sports betting, video gaming and illegal operators, together with a new set of red flag indicators for governments, regulators and the private sector.

What the FATF looked at

The report, Risks of Gaming and Gambling, covers land-based and online casinos, sports and novelty betting, other non-casino gambling such as scratch cards, arcades, bingo, lotteries and slot machines outside casinos, online video and mobile gaming, and illegal operators. 

It draws on questionnaire responses from 80 jurisdictions across the FATF Global Network, written comments from 29 jurisdictions, and consultation with industry bodies, researchers and private sector stakeholders. The project ran over the course of a year and is the FATF’s first detailed examination of risks tied to online and illegal gambling; its previous work on the sector, in 2009, was focused on casinos.

Where the risk sits

Money laundering through gambling is described as an established risk in many jurisdictions, but exposure is uneven:

• Brick-and-mortar and online casinos and sports betting are treated as the most exposed verticals
• Lotteries, scratch cards and some other non-casino products are considered less exposed by some jurisdictions
• Laundering through video gaming appears to happen on a smaller scale, and with less sophistication and frequency, than through gambling
• Terrorist financing linked to gambling remains limited and is reported infrequently, while the online gaming space showed more observable and documented misuse
• Proliferation financing risks remain very limited across both sectors, although the FATF notes the vulnerability exists 
• junkets are in decline and face increasingly strict regulation, but are still considered to pose risks around player anonymity and obscured beneficial ownership of the junket operator 

Illegal gambling named one of the sector’s most significant risks

The FATF identifies illegal gambling as one of the most significant risks in the sector. 

In many jurisdictions, it says, illegal markets rival or even exceed the size of legal ones, and illegal operators are present regardless of whether gambling is legal locally or how the market is regulated. 

Unlicensed offshore sites present themselves as legitimate businesses while offering anonymity and incentives that appeal to consumers.

The report also points to regulatory arbitrage, with criminals exploiting the gaps between national frameworks. Those same gaps, it notes, make information sharing between the public and private sectors harder and complicate international co-operation.

The five red flag categories

The indicators are grouped into five categories, split between land-based and online activity where relevant.

Payments, ownership and social media

Cash, e-wallets, mobile money and virtual assets are all named as vulnerable, and the report notes that the mix of payment options accepted by online operators increasingly allows rapid, anonymous, cross-border transactions and the conversion of value into different forms. 

Ownership is the second pressure point: the FATF warns that shareholdings can be structured specifically to stay below the thresholds that trigger regulatory checks, particularly where AML/CFT controls and anti-corruption frameworks are weak. 

Social media is treated as part of the problem rather than an adjacent channel, linked to coordinating competition manipulation, advertising illegal gambling, recruiting money mules, and terrorist propaganda and fundraising.

Giles Thomson, FATF President, said: 

‘Without robust safeguards, these sectors can be attractive gateways for fraudsters, professional money launderers and organised criminal networks. I urge all governments to take note of the risk indicators we have set out today, and put in place appropriate risk-based responses – from strengthening oversight and cracking down on illegal and offshore operators, to boosting international co-operation, and deepening public-private collaboration.’

What the FATF wants governments to do

The report suggests a number of recommendations to jurisdictions. These include:

• Improving risk awareness and applying a risk-based approach in line with Recommendation 1 of the FATF Standards
• Strengthening licensing and registration requirements to prevent criminals controlling gambling operators
• Raising awareness of the risks among service providers and the general public, particularly around illegal and unlicensed offshore gambling
• Strengthening formal and informal international co-operation between agencies, especially on online, illegal and cross-border gambling activities
• Considering developing or strengthening public-private partnerships to enhance information sharing and enable quicker responses to emerging risks

How the indicators should be used

The FATF is explicit that the list is not exhaustive and that a single indicator is not in itself a clear sign of illicit activity, though several together warrant closer examination. 

Some indicators may point to problem gambling rather than deliberate criminal conduct, and the report accepts that the two can co-exist in the same account. 

Most were drawn from land-based and online casinos and, to a lesser extent, betting; few were submitted for video games, so the closest equivalents from casino and betting platforms are applied instead. Further operational material and case studies are available to public authorities through the FATF’s secure platform.

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