The Financial Action Task Force has published new findings on illicit-finance exposure across casinos, betting services and online gaming as these businesses become increasingly digital and cross-border. The September 9 report focuses on money laundering, terrorist financing and, to a lesser extent, proliferation-financing risks, while providing risk indicators rather than treating specific technologies or transactions as inherently illicit.
According to the official FATF report on gaming and gambling risks, the project drew on questionnaire responses from 80 jurisdictions, written comments from 29 jurisdictions and consultations with industry participants and researchers. FATF identifies online and illegal gambling as an increasingly important supervisory challenge, with virtual assets, e-wallets, mobile money, cash and bank transfers forming part of a broader value-transfer ecosystem.
Red Flags Extend From Identity to Fund Flows
The indicators cover customer profiles, account behavior, betting patterns, payments and platform structures. FATF highlights activity such as multiple accounts, mismatched customer and payment details, deposits followed by withdrawals with little or no play, and multiple small deposits consolidated into larger withdrawals. Repeated VPN use, third-party funding and attempts to bypass customer due diligence can also warrant additional examination.
Virtual assets appear directly among the payment-related indicators. FATF references their use alongside prepaid cards, vouchers and e-wallets, while also highlighting transactions connected with higher-risk jurisdictions and unlicensed platforms. Crypto use by itself does not establish money laundering, and FATF explicitly says a single red flag is not necessarily evidence of illicit activity. Several indicators surrounding the same customer or transaction can instead justify further scrutiny.
That distinction matters for blockchain compliance teams. A SlowMist analysis of the FATF report argues that VASPs should combine on-chain exposure with source-of-funds information, counterparties and historical transaction behavior. The operational objective is contextual risk assessment rather than automatically treating a gambling-related wallet label as proof of wrongdoing.
Licensing Gaps Raise Compliance Pressure
FATF also found significant differences in AML/CFT supervision, licensing regimes and market-entry controls between jurisdictions. Its recommendations center on stronger risk-based oversight, licensing requirements, international cooperation and public-private information sharing, particularly for online, illegal and cross-border gambling activity.
Those concerns overlap with enforcement affecting prediction markets. Spain’s DGOJ opened proceedings against Polymarket and Kalshi in May and ordered a precautionary website block, saying they lacked the required gambling authorization. The temporary block of Polymarket and Kalshi in Spain also centered on safeguards including identity verification and restrictions for minors and self-excluded users. The case illustrates how local gambling rules can impose requirements independently of a platform’s regulatory status elsewhere.
The compliance trend extends beyond gambling. Recent developments have included tougher crypto AML approaches in China and U.S. sanctions targeting crypto-linked laundering networks, while prediction markets continue facing jurisdictional disputes over whether particular products fall under gambling or financial-market rules. For virtual-asset businesses, FATF’s report adds sector-specific warning signs to an already expanding compliance perimeter.
The next milestone is how jurisdictions implement the findings. FATF is calling for risk-based supervision rather than a uniform prohibition, leaving national authorities to translate the indicators into licensing, monitoring and enforcement practices. For online operators using multiple payment rails, the practical test will be whether customer behavior, source-of-funds checks and beneficial-ownership controls evolve alongside increasingly cross-border gaming ecosystems.
