From Euros to Pounds: Anti-money laundering legislation changes reshape casino compliance

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (“the 2026 Regulations”) were made on 9 June 2026, having been approved by both Houses of Parliament. 

For details on these changes, please read our article which considers the evidenced approach to risk which the Regulations impose.

The majority of the changes brought in by the 2026 Regulations relate to financial services and credit institutions authorised by the Financial Conduct Authority and in particular crypto asset providers. Many of the provisions relating to crypto asset businesses will commence when the forthcoming Financial Services Market Act 2000 cryptoasset authorisation regime comes into force.

However, there are changes to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“the 2017 Regulations”) that apply to all AML regulated sectors, including casinos. 

Most of those changes commence on 30 June 2026 (21 days after  the 2026 Regulations were made.) Therefore, the holders of Operating Licences,  for non-remote casinos, remote casinos and the holders of Casino Game Host Licences,  have just over 2 weeks to implement the three changes that apply to the casino sector.

 Currency Thresholds (Regulation 27)

Probably the most significant change for the casino sector is that all references in the 2017 Regulations to “euros” are replaced by fixed Sterling equivalents. 

Therefore the €2000 threshold under Regulation 27(5), which triggers the requirement for a casino to undertake customer due diligence measures will change to £2000. This will certainly assist land-based casinos who have had to keep their policies and procedures under review where there were exchange rate fluctuations. Land-based casinos had to select a sterling equivalent for undertaking customer due diligence that would prevent the customer exceeding the €2000 limit. However, this will prove to be more challenging for remote casino operators based in the EU as the threshold will reduce to approximately 1666 euro for UK customers.

 The UK government was obliged to adopt the €2000 figure because the 4th EU Directive was passed whilst the UK was still a member and so the then government was obliged to transpose the figure of 2000 euros into the UK National Legislation in June 2017.   

 High Risk Third Countries (Regulation 33)

Regulation 33 (1)(b) of the 2017 Regulations, “Obligations to undertake Enhanced Customer Due Diligence (“ECDD”)”, is amended in respect of high risk third countries. 

Going forward ECDD measures will be mandated where the relevant transactions or customer relationships involve a person established in a High Risk Third Country included in the Financial Action Taskforce’s (“FATF”) “Call for Action” country list and not FATF’s “Increased Monitoring” List. 

The Treasury explain in their Policy Note, published on 2 September 2025, that this will ensure that regulated firms can direct their resources to countries which present the greatest risk to the UK.

 In the Gambling Commission’s Notice published on 9 June it states that this will represent a more risk-based approach which will enable casinos to focus on the money laundering and/or terrorist financing threats faced specifically by the UK.

 Casinos will still be required to apply ECDD measures based on geographical factors, as referenced in Regulation 33(6)(c) of the 2017 Regulations, which lists several sources which regulated firms must take into account when assessing geographical risk, including both FATF lists and other relevant FATF assessments and evaluations. Both lists are up-dated three times a year on the final day of each FATF Plenary Meeting, held every February, June and October.   

 Unusually Complex and Unusually Large Transactions

The 2026 Regulations also make changes to Regulation 33(1)(f), which requires ECDD to be conducted when a transaction is complex or unusually large. The requirement is amended to add “unusually” complex transactions instead of all complex transactions. The requirement to undertake ECDD on unusually large transactions remains unchanged. 

The Treasury state in their Policy Note that the current wording leads to confusion and in some sectors an overly cautious approach. The change refines the previous requirement to ensure that firms can focus compliance on transactions that present genuinely higher risks to avoid having to expend resources on routine transactions that do not warrant additional security.

 The revisions represent changes in circumstances that will require a review of AML risk assessments under Licence Condition 12.1.1 and then a review of AML policies and procedures. The risk profiling becomes more UK specific, which could prove to be a challenge for remote operators based in EU jurisdictions because it will be necessary to specifically review the risk basis in the UK as opposed to an EU wide approach.

In its Notice dated 9 June 2026 the Gambling Commission confirms it will be reviewing its guidance to casinos on the prevention of money laundering and combatting the financing of terrorism and will be reviewing the section on the establishment of a business relationship.