Running a business in the financial sector means you probably need to register with an anti-money laundering scheme. This is because you are exposed to threats from bad actors who may target your business to make ill-gotten gains appear legitimate.
One lucrative area is the gaming and gambling sector, which offers several opportunities to launder money.
Recently (September 2026), the Financial Action Task Force (FATF) created a report which highlights new opportunities that have emerged for money laundering within the gaming and gambling sector, and how to spot them.
Varied payment methods
Gaming and gambling platforms sometimes offer a wide range of payment methods, such as virtual tokens bought with real money stored in an e-wallet, which can then be used to purchase virtual assets.
These varied payment methods can disguise the source of funds; after all, the user is purchasing an item, such as virtual tokens.
Bad actors can buy tokens on the platform, play a few games of their choice, and then convert the tokens back into legitimate currency, much like a legitimate user would. Distinguishing a valid user from a bad actor is where the risk becomes evident, especially if identity verification checks are relaxed.
In-game chat features
Although typically moderated, in-game chat features can enable coded communication between bad actors, letting them coordinate efforts and discuss plans. These plans can involve money-laundering activities, such as recruiting money mules; however, they can also include terrorist propaganda. Platforms that relax chat moderation or lack official oversight are more likely to be targeted.
While this alone can raise anti-money laundering concerns, in-game chat features can also be used in other ways.
One such way is to advertise illicit or unlicensed gambling platforms. Illegal or offshore gambling platforms in themselves create a significant risk for money laundering, with, in some countries, a larger market share than genuine gambling platforms.
Illegal offshore gambling platforms
In some countries, the illegal gambling market can exceed the legal market, meaning there is a greater chance the platform being used is illegal and unregulated.
Users are drawn to these platforms because they may offer greater levels of confidentiality, possibly because the jurisdiction has more relaxed money-laundering regulations. While this may not pose a risk to users who are unaware they are using an unregulated platform, bad actors can take advantage of the confidentiality to move their funds.
How can gaming and gambling platforms mitigate risks?
Like all forms of anti-money laundering, online gaming and gambling platforms should look at risk factors of doing business with certain individuals and identify those who are high-risk. As gaming and gambling platforms are based on user accounts, there are several unique risk factors you need to account for.
- Detected virtual private network (VPN) use could signal an individual attempting to conceal their location
- The IP address shows multiple accounts at the same address, or using the same provider
- The customer is based in a country where gambling is illegal
- The customer is reluctant to, or refuses to, appear on a video call to verify their identity
- Account details are frequently changed (including phone number, address or linked bank account)
- Bank details do not match the details provided by the customer
- The customer is reluctant to provide up-to-date identification documents, and those that are provided are unclear or have discrepancies
- The customer is highly interested in the account limits and any controls in place
- A previously inactive account has a sudden, one-time, large deposit made into it
- Suspected collusion if customers often play against the same individual(s) where one always wins, and the other always loses
- Repeated attempted withdrawals which are just under the limit required for customer identification
- Numerous daily deposits into the account
- The customer attempts to withdraw funds into a different account from where they originated
This isn’t a full list of the risks posed to the gambling and gaming sector, but they are a good place to start. For a full list of the risks along with areas of concern, check out the FATF Report - Risks of Gaming and Gambling.