money laundering; UK; betting; gambling; FOBT's; Fixed-odds betting terminals; Gambling Commission; bookmakers; regulations; money laundering directive; proceeds of crime; betting shops


Gaming and Casino Operations Management | Gaming Law

Document Type

Original Research Article


The purpose of this exploratory study was to generate an understanding in to the money laundering threats, vulnerabilities and controls found within UK betting shops, with a direct focus on the exponential growth of Fixed-Odd Betting Terminals. Qualitative research methods facilitated eight semi-structured interviews with key stakeholders linked to the gambling and/or money laundering sphere. This included the Gambling Commission, Campaign for Fairer Gambling, an ex-Head of Security and Safety at a major bookmaker, and five regular Fixed-Odd Betting Terminal users. The interviews were recorded, transcribed and coded for thematic analysis, subsequently resulting in the emergence of four interesting and meaningful themes. These were (1) Ineffective CDD enforcement facilitating anonymity (2) Weak anti-money laundering safeguards unable to mitigate known threats (3) A lack of anti-money laundering training, awareness, and resources (4) The Gambling Commission’s attempt for increased anti-money laundering regulation unsuccessful. By allowing a phenomenological framework to guide the data collection process, the interpreted subjective views and experiences of the participants involved, although somewhat limited, indicate that money laundering threats within the bookmaker sector are inherently high, with a lack of effective safeguards in place to mitigate the identified vulnerabilities.

Funding Sources

No funding was requested or received before, during or after this study was conducted.

Competing Interests

No funding was requested or received before, during or after this study was conducted.