Cryptocurrency risks and gambling sector under renewed scrutiny in updated AML strategy
Overview: Evolving Threat Landscape Prompts Strategic Response
The UK Government has unveiled its 2025 National Risk Assessment (NRA) on Money Laundering and Terrorist Financing, identifying rapidly evolving threats within the financial system, particularly those linked to cryptocurrencies, digital finance, and online gambling. This marks the fourth edition of the UK’s flagship AML (Anti-Money Laundering) and CTF (Counter-Terrorist Financing) framework, and it plays a critical role in shaping national security, compliance expectations, and law enforcement efforts.
The assessment comes amid growing concern over technological innovation outpacing regulation, especially in sectors vulnerable to illicit abuse. According to the Treasury, the very openness that makes the UK attractive for business can also serve as an entry point for criminals and terrorist groups to launder money, move illicit funds, and conceal identities.
Cryptocurrency and Tech-Driven Crime on the Rise
One of the most notable concerns in the report is the escalating use of cryptocurrencies and decentralised finance (DeFi) to obscure financial flows. The Government identifies crypto as an increasingly attractive tool for money laundering due to pseudo-anonymity, borderless transferability, and the lack of standardised oversight.
While previous risk assessments acknowledged the presence of digital currencies, the 2025 NRA elevates their threat level due to the rise in ransomware attacks, fraud schemes, and illicit peer-to-peer transfers across blockchain networks. These developments challenge traditional AML tools and call for stronger risk-based approaches in crypto exchanges, wallet services, and fintech platforms.
Gambling Commission to Revise Industry Risk Ratings
In direct response to the NRA’s findings, the UK Gambling Commission has committed to updating its risk assessment for the gambling sector. This follows increased scrutiny of high-value customer schemes and VIP player incentives, which have historically been linked to weak due diligence practices and vulnerabilities to exploitation by criminal actors.
The Commission’s review will focus on:
Player due diligence and affordability checks
Source of funds verification
Enhanced monitoring of digital and online gambling activities
Risk associated with cryptocurrency use in gambling platforms
Operators are advised to prepare for stricter compliance obligations as regulators work to realign the gambling sector with national AML priorities.
Integration with Broader Economic Crime Strategy
The NRA is part of the UK’s wider initiative under the ‘Strong Foundations’ pillar of the Plan for Change, reinforcing inter-agency cooperation between the Home Office, HM Treasury, and supervisory bodies. It aligns closely with the:
Economic Crime Plan 2023–2026
Contest 2023 Counterterrorism Strategy
Forthcoming Anti-Fraud and Anti-Corruption Strategies
The report also reaffirms the UK’s adherence to international standards set by the Financial Action Task Force (FATF), and its commitment to balancing national security priorities with an open financial ecosystem.
Conclusion: Heightened Expectations for Regulated Sectors
The 2025 National Risk Assessment marks a significant shift in the UK’s AML/CTF posture, emphasising the need for adaptive regulation in the face of technological disruption. With cryptocurrencies, online gambling, and cross-border platforms at the forefront of regulatory concern, businesses in these sectors are expected to implement robust risk management frameworks and demonstrate clear compliance pathways.
As the UK positions itself as both a tech innovation hub and a global AML leader, it’s clear that proactive supervision—not reactive policy—will define its success in neutralising financial threats.
