The Financial Action Task Force cautions that the gaming and gambling sectors are increasingly vulnerable to money laundering, terrorist financing and other forms of criminal abuse as online platforms, cross-border activity and digital payment methods continue to expand.
In its September 2026 report, Risks of Gaming and Gambling: Red Flag Risk Indicators, FATF discusses warning signs that governments, regulators, gambling operators and other private-sector bodies can use to identify suspicious activity.
The analysis was based on data from 80 jurisdictions, as well as contributions from 29 jurisdictions and input from industry bodies, researchers and private-sector stakeholders. It examined risks across casinos, sports and novelty betting, other gambling activities and online video and mobile gaming.
Illegal Gambling is Seen as Major Risk
FATF identified illegal and unlicensed gambling as one of the sector’s most significant risks. Analysis determined that illegal gambling markets can rival or even exceed legal markets in some countries, while offshore operators continue to attract customers via promotions and greater levels of confidentiality.
The organisation also highlighted the growing complexity of the gambling ecosystems and models. More online and land-based operators are using a combination of payment methods, including cash, cards, bank transfers, e-wallets, mobile money and virtual assets.
According to the FATF, these payment methods can enable rapid and anonymous cross-border transactions and allow funds to be converted into different forms of value. Online casinos are also increasingly connected to social media and other digital services, creating further opportunities for criminal misuse.
Using Gambling Accounts to Move Money
One of the key concerns identified in the FATF report is the use of gambling platforms to move money without actual gambling activity.
The report documents non-genuine play patterns as a potential warning sign, particularly where large amounts are deposited and withdrawn while almost no funds are wagered. Deposits followed by withdrawals with minimal or no gambling activity in between may also call for further examination.
Other signs can be frequent transfers between several individuals, prompt changes in the amounts deposited or withdrawn, and inactive accounts that suddenly receive large deposits which don't correspond with their previous history.
The FATF also labels the structuring of deposits into smaller amounts to remain below reporting thresholds. Multiple small deposits from different sources that are later consolidated into larger withdrawals are another potential indicator of suspicious activity.
Looking into Suspicious Betting Patterns
Furthermore, the report identifies several betting behaviours that may require closer monitoring.
These include sudden increases in betting amounts or frequency, spending inconsistent with a user’s declared income, coordinated betting and activity involving bets on multiple possible outcomes.
The FATF also highlights unusually large or harmonised bets on events already marked by sports-integrity bodies or monitoring services for potential match fixing. Highly improbable and sustained winning streaks can also suggest insider information or corruption.
However, FATF stressed that a single indicator should not be trusted to conclude money laundering or terrorist financing attempts. Several indicators relating to the same customer or transaction should prompt further monitoring and examination. These signs could also mean problem gambling rather than deliberate attempts at criminal activity.
Multiple Accounts and Payment Methods Cause Concerns
Online casinos and gambling platforms are also increasingly exposed to complex customer and payment behaviours.
For example, repeated VPN use, multiple devices, discrepancies between a customer’s residence and detected location, and attempts to open several accounts under the same or false names can be among the warning signs.
The report also identifies cases where betting account details do not match the payment method used for deposits or withdrawals. Several accounts operating from the same IP address or device may also require further investigation.
There are also payment-oriented indicators that can feature multiple payment methods registered under different names, withdrawals to accounts not related to the source of funds, international or virtual-asset withdrawals conflicting with a player’s location, and deposits made by unrelated third parties.
Operators Susceptible to Exploits
The FATF has also warned that criminal risks can extend beyond customers and can involve gambling operators.
Complex ownership structures with nominees, trusts and foundations can conceal beneficial ownership. The report also alerts that shareholdings may be structured to remain below regulatory thresholds, especially in cases where AML and anti-corruption controls are ineffective.
Other warning signs are unexplained profitability or quick financial growth, questionable ownership transfers, frequent changes to company or brand names and operators based in jurisdictions with weaker AML/CFT protocols.
The FATF also underlined the use of the so-called ‘sham merchants’, through which illicit operators can disguise themselves as legitimate businesses to process gambling-related payments that appear to be regular retail transactions.
FATF Seeks Enhanced Cooperation
Lastly, FATF discussed how differences between national regulatory frameworks can allow operators to exploit gaps between jurisdictions while making information sharing and international enforcement challenging.
Therefore, it recommends stronger licensing and registration requirements, greater awareness of gambling-related financial crime risks and increased international cooperation, specifically around online, illegal and cross-border gambling.
The FATF also called for stronger public-private partnerships to improve information sharing and enable faster responses to new threats.
“Without robust safeguards, these sectors can be attractive gateways for fraudsters, professional money launderers and organised criminal networks,” FATF President Giles Thomson said.
He urged governments to adopt the new indicators and embrace risk-based responses, such as stronger oversight, action against illegal and offshore operators, greater international cooperation and deeper public-private collaboration.
The FATF said its indicators are intended to help authorities and businesses identify, assess and respond to suspicious activity across gaming and gambling. It stressed that the list is not exhaustive and that indicators should be considered in context rather than treated as proof of criminal conduct.
