FATF publishes new list of risk indicators for AML/CTF concerns covering online and land-based
The Financial Action Task Force (FATF) has published new risk indicators including how money is moved through online gambling platforms and the risk of anonymous transactions across borders.
In a recent report, the global financial watchdog, whose ratings of countries’ anti-money laundering and counter-terrorist financing (AML/CTF) frameworks have sizeable impacts on nations’ global status and ability to engage with foreign financial systems and governments, provided its “irst detailed examination of risks associated with online and illegal gambling.”
Amongst the findings, the FATF noted that “Online gaming and gambling platforms are also increasingly interlinked with social media and other digital platforms which can increase ML/TF/PF (money laundering/terrorist financing/proliferation financing) risks.”
The group furthered that “llegal and unlicensed offshore gambling is cited as a significant risk. The illegal gambling market rivals or even exceeds the legal market in some countries and continues to proliferate, attracting players through promotions and greater levels of confidentiality.”
The group provides the traditional warnings regarding improved licensing procedures and raising awareness on illegal and unlicensed offshore gambling, but it highlights some key areas to pay attention to regarding online gaming.
Amongst these are identity concealment through VPN, multiple device use and user location data discrepancy, attempts to open multiple accounts under the same name or a fake name, payment and betting account details not matching, IP address and stated location mistmatch, multiple players from the same IP address, customers being based in countries where gambling is illegal, refusal for video calls to verify identiy, attempts to re-open or re-register previously suspicious or closed accounts and customer account images or symbolism that promotes extremist views.
The group also draws significant attention to how online accounts of players are handled, warning that unusual transfers or deposits, changes in account use, frequent deposits from unverifiable sources, inactive accounts receiving large deposits and other activity can be key signals of bad actors.
Player betting behavior was also highlighted – focusing on both online and land-based, with the FATF highlighting typical behaviors that should draw attention – including collecting winnings just below the customer identification threshold, structuring bets into smaller amounts to fall under reporting thresholds and coordinated or unusual betting activity.
A significant number of individual warnings are included in the FATF list, with operators, regulators and players urged to pay attention.
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The Backstory
Global scrutiny returns to gambling’s weakest points
The Financial Action Task Force’s latest warning on gambling risk lands at a time when regulators are trying to expand legal digital markets without reopening channels for money laundering, terrorist financing and related financial crime. Its new indicators focus on conduct that has become common in online wagering: concealed identities, mismatched payment details, repeated account creation, unusual deposits, coordinated betting and cross-border play through offshore platforms.
The importance of the guidance is not limited to compliance departments. FATF assessments affect how countries are viewed by banks, investors and counterpart governments. A weak rating can raise the cost of doing business and complicate access to the global financial system. For gambling regulators, that means the sector’s controls are no longer a narrow industry issue. They are part of a country’s broader financial integrity profile.
The timing is especially relevant in Asia, where governments have taken diverging approaches. Some are trying to pull players into supervised markets. Others are relying on blocking, payment freezes and criminal enforcement. FATF’s message cuts across both models: online gambling creates identifiable risks, but those risks are manageable only where operators, payment firms and regulators can see the transactions.
The Philippines shows the reward and burden of leaving the grey list
The Philippines offers the clearest recent example of the stakes. The country was removed from FATF’s grey list after reforms to its anti-money laundering and counter-terrorist financing framework, a development that Moody’s said should support investor confidence and financial stability. But Moody’s also cautioned that online gambling and cryptocurrency remain areas requiring continuous oversight.
That warning reflects the nature of FATF compliance. Exiting increased monitoring does not end scrutiny. It raises expectations that reforms will be maintained and tested against changing risks. PAGCOR Chairman and Chief Executive Alejandro Tengco said at the time that the regulator would continue to ensure licensees comply with AML rules across online gaming operators, land-based casinos and junket operators.
The country’s legal remote gaming structure, often described as PIGO, is designed to serve only players located in the Philippines who are registered with licensed gaming entities. That domestic focus is meant to support supervision. But the same market is exposed to risks that FATF now highlights: remote onboarding, digital payments, player location questions and the persistent pull of offshore operators that are not subject to Philippine licensing conditions.
PAGCOR’s sector review pointed to the same vulnerabilities
Before FATF’s latest report, the Philippine regulator had already pushed operators to reassess their controls. PAGCOR directed casinos, electronic gaming operators and support service providers to review their risk models after a Casino Sector Risk Assessment covering 2021 to 2024 found the gaming sector was high risk for money laundering and medium risk for terrorism financing.
That directive required companies to circulate the assessment to directors, management, compliance officers, internal audit teams and frontline staff. Operators were told to review customer due diligence, source-of-funds checks, transaction monitoring and suspicious transaction reporting. The regulator singled out junket relationships, high-value transactions, cash activity, VIP play, remote channels and weak controls as areas of concern.
The overlap with FATF’s new indicators is significant. FATF points to inactive accounts receiving large deposits, deposits from unverifiable sources, multiple users linked to the same IP address, discrepancies between stated and actual location and attempts to evade identification thresholds. PAGCOR’s earlier review similarly treated remote channels, electronic gaming and inadequate source-of-funds verification as points where criminal proceeds can enter the regulated system.
The practical result is that licensed operators face a higher compliance burden, while regulators are expected to examine whether risk reviews lead to measurable improvements. PAGCOR has warned that inadequate compliance may lead to administrative sanctions. For licensed companies, FATF’s report strengthens the case for investment in monitoring systems, payment screening and staff training. For regulators, it adds an international benchmark against which domestic enforcement will be judged.
Advertising fights are really channelization fights
The Philippine debate over gambling advertising shows how AML policy, consumer protection and market structure now intersect. A proposed total advertising ban has been criticized by industry participants who argue it would weaken the licensed sector and hand customers back to offshore operators. A recent analysis warned that a full ban could reverse gains made in moving Filipino players from illegal sites to supervised platforms, citing data from several countries and the government’s own enforcement record.
The channelization argument matters for FATF purposes. Regulators can monitor bets, payments and player identities only when activity occurs inside the licensed market. If advertising restrictions make legal operators less visible while illegal sites continue to promote through social media, messaging apps and influencers, more play may migrate to platforms beyond the reach of know-your-customer checks, exclusion lists and suspicious transaction reporting.
The Philippines has spent several years trying to shift online wagering into legal channels. PAGCOR cut e-games license fees, required KYC-verified payments, accredited parts of the supply chain and increased enforcement against illegal sites. The analysis of the proposed advertising ban argued that those steps helped legal platforms take a larger share of online play and gave the state greater visibility over transactions.
That visibility is central to FATF’s concerns. A legal operator can be fined, audited, ordered to stop promotions and required to report suspicious behavior. An illegal offshore operator cannot be disciplined through licensing tools. Blocking and payment disruption can limit access, but mirror domains and alternative payment routes can appear quickly. A policy that reduces the legal market’s ability to reach customers may therefore have AML consequences, not just commercial ones.
Indonesia illustrates the payment trail problem
Indonesia has chosen a more prohibitive approach because online gambling is illegal. Its financial intelligence agency, PPATK, recently blocked more than 28,000 bank accounts suspected of involvement in online gambling transactions. Authorities said some accounts were bought or sold to hold funds for illegal operators, while others were dormant accounts later used to move gambling-related money.
The Indonesian crackdown demonstrates why FATF emphasizes account behavior. Dormant accounts receiving activity, unverifiable funding sources and unusual transaction flows can indicate misuse by gambling networks. PPATK’s action also showed the difficulty of broad financial enforcement. The freezes triggered public concern after some users reported account suspensions, prompting the agency to tell customers they could reactivate legitimate accounts through bank procedures.
For countries with legal gambling, the Indonesian experience is a cautionary example of what happens when transaction monitoring shifts mainly to banks and intelligence agencies after the fact. Licensed gambling operators can collect player data, match account and payment information, set thresholds and flag betting patterns in real time. Where gambling activity is pushed outside the regulated perimeter, authorities often rely on retrospective account freezes and criminal investigations.
Payments innovation adds transparency but not without risk
The FATF report also arrives as gambling payments become more specialized. New products are being built to reduce friction for bettors while improving visibility over funds. Edge Markets, for example, has developed a single-use Visa debit card for gambling transactions, arguing that a dedicated account can separate wagering funds from ordinary spending and create a clearer compliance trail.
The company says the product can be used only for gambling, must be linked to an account in the holder’s name and is subject to know-your-customer checks. That model reflects one possible response to the risks FATF identifies: make gambling payments more traceable, not less. A dedicated payment channel can help operators and financial institutions understand where funds come from and where they go.
But specialized payments also underscore why controls must cover the full ecosystem. FATF’s indicators do not stop at casino operators. They implicate payment providers, affiliates, digital platforms and any service that helps move money or acquire customers. As gambling becomes more digital, the compliance perimeter expands.
The core lesson from the related developments is consistent. Countries gain more control when gambling activity is licensed, visible and tied to verified identities. They lose it when players move to offshore sites, anonymous accounts or payment channels beyond supervision. FATF’s new risk indicators give regulators a sharper checklist. The harder task is preserving enough of the legal market for that checklist to matter.
