Licensed online gambling groups operating in both the United Kingdom and Germany are subject to two distinct anti-money laundering (AML) supervisory architectures. The distinction is reflected in the allocation of statutory responsibility, the structure of reporting obligations, and the implementation of monitoring mechanisms under law.

This article presents a structural mapping of these frameworks based exclusively on statutory texts and official supervisory publications. No interpretive grading or comparative assessment is included.

Allocation of Supervisory Responsibility

In Great Britain, the Gambling Act 2005 designates the UK Gambling Commission (UKGC) as the regulator of licensed gambling activities. Casino operators are classified as “relevant persons” under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended). Accordingly, they are subject to AML obligations prescribed by law, including firm-wide risk assessment (Regulation 18), customer due diligence, enhanced due diligence where required, ongoing monitoring, and suspicious activity reporting pursuant to the Proceeds of Crime Act 2002.

Under the UK regulatory structure, AML monitoring and internal controls are implemented at operator level and supervised by the UKGC pursuant to its mandate, including licence conditions, compliance assessments, and published enforcement outcomes.

In Germany, the Glücksspielstaatsvertrag 2021 (GlüStV 2021) establishes the Gemeinsame Glücksspielbehörde der Länder (GGL) as the competent supervisory authority for licensed online gambling. In parallel, the Geldwäschegesetz (GwG) classifies operators of games of chance as obligated entities (Verpflichtete) and subjects them to AML requirements defined by statute, including institutional risk analysis, due diligence measures, ongoing monitoring, and suspicious transaction reporting to the Financial Intelligence Unit (FIU Germany).

Beyond the AML obligations under the GwG, GlüStV 2021 establishes centralized monitoring systems, including LUGAS (Länderübergreifendes Glücksspielaufsichtssystem) and OASIS (national self-exclusion system). Licensed operators are required to integrate with these systems in accordance with legal provisions.

The allocation of supervisory responsibility in each jurisdiction determines how AML controls are implemented and which authority reviews compliance.

Reporting Architecture

In the United Kingdom, suspicious activity reports (SARs) are submitted to the National Crime Agency (NCA) under the Proceeds of Crime Act 2002 and associated regulations. The reporting obligation arises where an operator knows or suspects, or has reasonable grounds for knowing or suspecting, that a person is engaged in money laundering, as defined by law.

Under German law, obligated entities must submit suspicious transaction reports to the Financial Intelligence Unit pursuant to the Geldwäschegesetz. The reporting obligation is triggered in accordance with the GwG.

For operators active in both jurisdictions, this results in reporting relationships with distinct competent authorities operating under separate legal mandates.

Group-Level Compliance Governance

For corporate groups holding licences in both jurisdictions, the allocation of AML responsibility differs in structure.

Within the UK system, AML supervision of licensed gambling operators is integrated into the mandate of the UK Gambling Commission, while suspicious activity reporting is directed to the National Crime Agency.

Within the German system, AML obligations arise under the Geldwäschegesetz, while gambling supervision is exercised by the GGL pursuant to GlüStV 2021, alongside the operation of centralized monitoring systems established by law.

Accordingly, compliance governance at group level must align with jurisdiction-specific legal structures. Internal control systems, documentation standards, reporting procedures, and monitoring integrations must reflect the supervisory architecture applicable to each licensed entity.

These structural distinctions do not alter the requirement to comply fully with the law in each jurisdiction. However, they determine how compliance responsibilities are distributed and supervised within a multi-license corporate structure.

Concluding Observation

A structural comparison of the United Kingdom and Germany confirms that AML supervision within the licensed online gambling sector is implemented through nationally defined legal and supervisory frameworks.

For multi-jurisdictional operators, effective compliance governance requires alignment with each jurisdiction’s defined legal structure rather than reliance on procedural uniformity across entities.

This mapping is derived exclusively from statutory texts and official supervisory publications. Detailed jurisdictional records are maintained within the GamingMarkets Regulatory Matrix.

Oren Dalal is the Founder & Publisher of GamingMarkets.com, an independent regulatory intelligence platform mapping statutory and supervisory frameworks across licensed online gambling jurisdictions. His work is grounded in primary-source legislative analysis, focusing on AML supervisory architecture and compliance governance in multi-jurisdictional groups.

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