Tackling unlicensed gambling is central to the UK Gambling Commission’s objective of preventing gambling from being a source of crime and disrupting this illegal activity at scale.

The Commission has become aware of casino games supplied by licensed operators appearing on unlicensed websites available to the British consumers illegally.

Those markets are unregulated, and do not provide the same safeguards that are required of operators. They often target vulnerable customers, such as those who have self-excluded via the GAMSTOP scheme. The websites may have inadequate social responsibility and Anti-Money Laundering (AML) controls in place and leave customers open to risks of fraud, data privacy issues and unfair practices. It is therefore imperative that the Commission, in collaboration with the gambling industry and key partners take all possible steps to mitigate risk to GB consumers.

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Operators providing Business-to-Business (B2B) gaming solutions including live games, live casinos and slots (B2B operators) can help the Commission tackle the illegal market by reviewing their own practices. The Commission has found that, in some instances, third party resellers are distributing games supplied by operators to the illegal market, often in breach of their contractual obligations. Commission licensees may have been negligent in allowing them to do so and in the process, place their own licence at risk.

The Commission advised operators to actively monitor their business relationships to ensure any partners are not participating in offering illegal gambling facilities to the GB market, and where identified, terminating relationships where non-compliance has occurred.

It is critical that licensees also actively engage with the Commission where such activity is identified, setting out the preventative measures adopted to ensure such activity ceases immediately. Actively notifying the Commission and setting out a clear plan to mitigate the issue at pace is a minimum requirement.

The Commission is adopting a proactive approach to this matter and may decide at any point to conduct test purchasing activity to evidence potential breaches.

The Isle of Man Gambling Supervision Commission has confirmed the appointment of Mark Rutherford as its new Chief Executive Officer.

His role is to oversee and maintain the Isle of Man’s regulatory standards for Gambling and Medicinal Cannabis and ensure the integrity, transparency and effectiveness of the Island’s regulatory framework, safeguarding both the reputation of the sector and the protection of consumers.

Having worked within the Isle of Man GSC for 15 years, Mr Rutherford’s experience spans multiple roles within the Island’s public service, including having served in the Income Tax Division before joining the GSC as the Director of Policy and Legislation.

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Acting chair of the GSC, David Butterworth, said: “I am pleased to announce the appointment of Mark as Chief Executive of the GSC. His transition into this role comes at a crucial time, ensuring we uphold the highest standards of transparency and protection while adapting to the sector’s evolving challenges.

“With his extensive experience and clear vision for improvement, Mark is a valuable asset who is committed to strengthening our regulatory approach to meet the Island’s needs and those of the sectors it represents well into the future.”

Mr Rutherford said: “I am grateful to the GSC Board for their confidence in me as CEO. I have lived and worked in the Isle of Man in both private and public sectors and my role as a public servant has been dedicated to serving the Isle of Man. I am committed to ensuring the effective, transparent and secure regulation of gambling and the production of medicinal cannabis here in the Island.

“There is an important opportunity to strengthen the Isle of Man’s defences against financial crime and I am embarking on an ambitious programme of reform to reinforce the powers we have to supervise and regulate the gambling sector. I am also working closely with partner agencies to understand the emerging threat that faces the Island’s gambling sector.

“It is imperative that we continue to review and adapt our approach to stay aligned with evolving challenges, including the emerging risks and typologies arising from particular markets. I shall be examining those threats closely to ensure that we are alert to them and manage the risk.

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“I will also be further expanding our international cooperation and domestic inter-agency working and the GSC will continue to play its part in the network of authorities that detect and disrupt criminal activity in the Island. It is vital that we maintain alignment with the international standards’ requirements for combatting financial crime as they continue to be evolve.

“Over the last 25 years the Island has built a global reputation as a high-quality regulatory regime for eGaming and we have seen the sector grow and diversify. I am keen that we support responsible growth in this important sector by licensing quality operators who share our values of safety and fairness.”

The Danish Gambling Authority has become aware that money laundering can occur through affiliates who market for gambling operators. Gambling operators that use affiliates should therefore consider whether this gives rise to updating their risk assessment.

An affiliate is a marketing channel where a person or company makes money by marketing for, for example, a gambling operator. The general consumer protection and marketing rules and the Gambling Act’s rules on marketing and communication also apply to affiliates. An affiliate earns money from the agreement by, for example, attracting new customers via their own website or through their own social network to the gambling operator’s website with a link. The link is generated specifically for the affiliate. The affiliate receives payment for the referral (pay per click), or a certain percentage of the amount the new customer deposits into their account.

How criminals can exploit affiliate agreements with gambling operators

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In affiliate agreements with an individual or a company, there is an inherent risk that a gambling operator will be misused for money laundering. Particularly organized criminal networks can exploit an affiliate agreement. Networks of organized criminals can refer a large number of people within their criminal network as customers using the link to a gambling operator. A larger amount of illegal funds can be deposited into customers’ gambling accounts, which will not initially look suspicious, as the amount is distributed among several people in the criminal’s network. The deposited funds can subsequently be paid out to customers, possibly after play-through from their gambling accounts. This approach will make it look like legitimate winnings from gambling, and at the same time the affiliate increases its profit by having brought more new customers to the gambling operator, who according to the affiliate agreement is usually paid per additional new customer.

Signs of money laundering through affiliates

The Danish Gambling Authority points out that gambling operators may risk being misused for money laundering through these affiliate agreements. It may indicate that a gambling operator is being misused for money laundering by its affiliate if a majority of the customers referred by the affiliate only use the gambling operator’s website once and then no longer use the gambling operator’s services. It may therefore be relevant to assess whether entering into an affiliate agreement gives rise to updating one’s risk assessment.