On 3 April 2025, the Gambling Commission provided a guidance update in respect of casinos that also provide money service business (“MSB”) services. The Gambling Commission explains in the update that “casinos offering services to customers including acting as a cheque casher or currency exchange, accepting winners’ cheques and foreign currency, or transmitting money are considered to be providing MSB services under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017” (the “MLR 2017”).

Under the MLR 2017, the Gambling Commission is the supervisory authority for casinos in the UK and HM Revenue and Customs (“HMRC”) is the supervisory authority for MSBs. Pursuant to Regulation 7(2) of the MLR 2017, where casino businesses also carry out incidental MSB activities, the Gambling Commission and HMRC have agreed that the supervisory body is the Gambling Commission.

The MLR 2017 requires HMRC to maintain a register of MSBs and therefore all casino businesses that also provide MSB services have to register.

The Gambling Commission points out that it intends to enter into an agreement with HMRC, under which the Gambling Commission will provide the necessary registration details directly to HMRC, so that affected licensees will not have to apply directly to HMRC to be on the register. Specific details will be shared by the Gambling Commission with HMRC to facilitate registration.

The Gambling Commission emphasises the importance of licensees’ compliance with their legal obligations “because it contributes to tackling the serious economic and social harm from organised crime. It also contributes to reducing the threat from terrorism in the UK and around the globe”.

It also highlights HMRC’s current guidance on meeting the requirements: Money service business guidance for money laundering supervision and Understanding risks and taking action for money service businesses.

The Gambling Commission will be providing more information on the agreement with HMRC in due course.

Please get in touch with us if you have any questions or require any assistance.