In the high-exposure worlds of online gaming, forex trading, and other high-risk, regulated industries, Anti-Money Laundering (AML) compliance is a strategic imperative. The stakes are steep: failure can lead to substantial fines, reputational harm, and even operational shutdown. Conversely, robust AML measures foster trust, safeguard market credibility, and support sustainable expansion.
Recent enforcement actions underscore this reality. One of the largest BNPL providers in the world was fined $50 million by Swedish authorities after regulators identified “significant deficiencies” related to anti-money laundering oversight. As the Financial Times reported: “The Swedish regulator said…not having any assessments of how its services could be used for money laundering or terrorist financing” (source: Richard Milne, Financial Times). In the words of the Swedish regulator, “The anti-money laundering regulations must be followed. It is important to counteract the risk that the firm’s operations could be used by criminals.”
For C-level executives and Heads of Payments, this is a clear call to action. By aligning with evolving UK and EU AML frameworks—and leveraging specialist support from providers like VIP360—firms can convert compliance demands into competitive advantages. Read further to learn how.
The UK regime, shaped by the Proceeds of Crime Act 2002 (POCA) and the Money Laundering, Terrorist Financing and Transfer of Funds Regulations (MLR2017), imposes stringent obligations on regulated entities. Financial Conduct Authority (FCA) guidance states: “Regulated firms are required to take a risk-based approach to customer due diligence and ongoing monitoring… including enhanced due diligence (EDD) and enhanced ongoing monitoring in higher-risk situations.” (source: FCA guidance document)
For high-risk industries like online gaming, where transactions frequently cross borders and involve potentially high-risk customer profiles such as Politically Exposed Persons (PEPs), the UK rules demand careful consideration. The UK authorities rely on POCA to prosecute money laundering, and the FCA, HM Revenue & Customs (HMRC), and the Gambling Commission, among others, serve as AML supervisors. According to recent guidance on UK AML laws and regulations: “POCA and the Regulations are the principal laws used to prosecute money laundering,” and under POCA, “three primary substantive money laundering offences” exist, all requiring that the property in question is ‘criminal property.’ (Source: ICLG, Anti-Money Laundering Laws and Regulations UK 2024)
Notably, regulated entities must maintain robust Know Your Customer (KYC) and Know Your Business (KYB) procedures, identify beneficial owners, and report suspicious activity promptly. Given the UK’s high-level stance on AML, non-compliance can trigger severe penalties. Under POCA’s primary money laundering offences, individuals can face up to 14 years’ imprisonment and/or unlimited fines, and corporates can be held liable if senior managers commit an offence within their scope of authority.
Meanwhile, the EU is introducing a new AML package designed to harmonise requirements and close loopholes. The Council of the EU has recently adopted a package of new anti-money-laundering rules to strengthen the fight against financial crime. According to the Council: “The new and stricter rules will strengthen our systems… a new agency based in Frankfurt will supervise the work of actors involved.” (Source: EU Council Press Release) This new authority, AMLA, will have “direct and indirect supervisory powers over high-risk obliged entities in the financial sector.”
The EU’s AML framework transforms previous directives into a directly applicable regulation, ensuring uniformity across member states. Notably, it brings into scope “most of the crypto-sector, traders of luxury goods and football clubs and agents.” The package also prescribes a €10,000 limit on cash payments, imposes tougher due diligence requirements, and introduces clearer rules on beneficial ownership reporting.
Abou Bangoura notes: “The EU’s revised AML regime… has introduced significant changes for financial services firms and other obligated entities.” (Source: Abou Bangoura, Cosegic, EU’s new anti-money laundering regime: what UK entities need to know). UK firms with EU operations must navigate two regulatory systems. This dual compliance burden heightens complexity and underscores the importance of building flexible AML frameworks.
The EU Council’s press release emphasises that AMLA will not only supervise financial institutions but also coordinate with non-financial sectors and support FIUs. Enhanced access to centralised bank account registers and an integrated mechanism with national supervisors will ensure “fraudsters, organised crime and terrorists…have no space left” for financial crime.
In both the UK and EU frameworks, businesses must apply Enhanced Due Diligence (EDD) in higher-risk scenarios. This includes dealing with PEPs, complex ownership structures, and customers from high-risk jurisdictions. The FCA states that EDD applies to customers linked to higher-risk countries, those with opaque beneficial ownership, and transactions that are large, unusual, or lacking an obvious economic purpose.
As we saw, in the EU, the new AML regulation expands EDD requirements. The package “extensively harmonises” rules and incorporates new obliged entities, including “most of the crypto-sector, traders of luxury goods and football clubs.” (Source: EU Council Press Release) This places online gaming operators—already accustomed to dealing with volatile, cross-border transactions—under even greater scrutiny.
Enforcement actions in 2024 demonstrate that regulators are increasingly willing to impose substantial penalties on businesses—both financial and non-financial—that fail to meet AML obligations. While some entities face relatively modest fines measured in tens of thousands of pounds, others incur multi-million pound or euro penalties. This spectrum highlights that AML shortcomings, whether minor oversight or severe structural failings, are receiving unprecedented scrutiny.
Recent fines in Europe offer a clear illustration. One major EU-based financial institution was penalised hundreds of millions of euros for inadequate AML controls, underscoring that even large, well-resourced entities are not immune. Another prominent European bank faced a substantial penalty after regulators identified critical lapses in due diligence processes, despite prior warnings. Meanwhile, a UK-based law firm incurred fines running into five figures for long-term non-compliance—an indication that professional service providers, not just banks, are firmly on regulators’ radars.
In the UK property sector, multiple estate agencies collectively received over £1 million in fines for ignoring registration requirements or neglecting key AML checks. Such penalties highlight a trend: regulators are targeting not just global financial institutions, but also smaller or mid-sized operators in areas like real estate and high-value goods. This inclusivity reflects a comprehensive approach, ensuring that any sector handling funds—particularly those associated with luxury products, gaming, and high-stakes transactions—is held accountable.
The gaming and casino sector, already under pressure due to its high-risk nature and complex customer base, has seen a major non-UK operator sanctioned with a fine of approximately $300 million for failing to manage risky clientele effectively. This case underscores that, for industries like gaming, the cost of overlooking AML duties can be truly damaging. With multi-jurisdictional oversight and heightened media attention, a single enforcement action can redefine an operator’s reputation and market standing.
Where compliance frameworks are weak—be it in verifying customer identities, monitoring suspicious transactions, or adhering to beneficial ownership transparency requirements—regulators have demonstrated their readiness to impose stern financial penalties.
All data and information above has been sourced from KycHub, What are AML Fines? – 6 Latest AML Fines of 2024.
Financial penalties are not arbitrary; regulators consider multiple factors before imposing fines. Authorities typically evaluate:
By examining these elements, regulators tailor penalties to reflect both the gravity of misconduct and the extent of systemic failures.
The escalation in AML fines goes beyond mere punishment; it aims to recalibrate industry norms. High-profile penalties serve as cautionary tales, incentivising firms—especially in sectors like gaming, forex, and luxury goods—to invest proactively in AML capabilities. Rather than waiting for enforcement actions, businesses are encouraged to embed compliance in their operational DNA.
This environment fosters a shift towards advanced technologies and stronger KYC/Customer Due Diligence (CDD) frameworks. With complex or opaque beneficial ownership structures under increasing scrutiny, firms must ensure they can identify and verify clients accurately, monitor transactions in real-time, and respond promptly to red flags. The surge in fines acts as a catalyst, nudging the industry towards more innovative, data-driven approaches to AML.
In this climate, strategic alliances with specialised providers can streamline compliance efforts. Solutions like those offered by VIP360—featuring integrated compliance checks, real-time monitoring, and automated alerts—help regulated entities maintain alignment with evolving standards. Robust technological support can transform AML from a reactive box-ticking exercise into a proactive, value-added function that prevents substantial fines down the line.
The intensifying regulatory climate and the surge in AML fines underscore the strategic importance of seeing compliance not as an administrative burden, but as a foundational pillar of long-term success. As noted by KYC Hub, “Compliance with AML regulations is necessary and very important to ensure a safe and secure financial system.” (Source: KycHub, What are AML Fines? – 6 Latest AML Fines of 2024)
For high-risk, high-revenue businesses, each enforcement action and penalty is a reminder that regulators are closely watching—and willing to impose substantial consequences. According to KYC Hub, “Fines can be issued for various reasons, such as failing to carry out customer due diligence or needing adequate systems and controls to monitor customer activity.” (Source: KycHub, What are AML Fines? – 6 Latest AML Fines of 2024) This points directly to the need for robust KYC/CDD frameworks and real-time transaction monitoring. By investing in advanced AML infrastructures and embracing best practices early, businesses can reduce their exposure to costly fines, reinforce credibility among stakeholders, and outpace less prepared competitors.
Ultimately, adopting a proactive AML stance can transform compliance into a competitive advantage. Aligning with cutting-edge AML solutions—such as those provided by experts like VIP360—ensures not only survival amid heightened scrutiny but also long-term strategic resilience and growth.
AML compliance also provides tangible benefits. Demonstrating robust controls reassures regulators and customers alike, nurturing trust in competitive markets. When clients know a platform maintains stringent AML measures, they feel safer depositing funds and spending money. Internally, compliance frameworks often streamline operations, enhance data quality, and inform strategic decisions—factors that boost efficiency and reduce long-term costs.
As UK AML laws evolve—such as the ongoing consideration of restructuring AML supervision—and the EU rolls out AMLA and the new AML regulation, the compliance landscape grows more complex. High-risk regulated industries must invest in flexible, tech-driven solutions. VIP360’s advanced payment infrastructures can support agile adaptation, ensuring compliance remains streamlined and cost-effective.
The Council’s adoption of the AML package illustrates the EU’s commitment to strengthening AML and counter-terrorist financing systems: “The regulation exhaustively harmonises anti-money laundering rules for the first time throughout the EU,” ensuring the entire private sector is covered. (Source: EU Council Press Release)
For gaming operators, anticipating these shifts and embedding best practices now can foster resilience. Compliance is no longer just a defensive measure; it can differentiate brands, reassure stakeholders, and enable cross-border expansion without regulatory friction.
In high-risk regulated sectors, AML compliance is the cornerstone of credibility, sustainability, and success. Recent fines and evolving frameworks in the UK and EU prove that regulators are relentless in closing loopholes, harmonising standards, and enforcing penalties for non-compliance. For gaming companies and other high-revenue regulated enterprises, ignoring AML is simply not an option.
By embracing the UK’s risk-based approach, meeting new EU-wide mandates, and partnering with specialists like VIP360, businesses can build a compliance architecture that safeguards their market position. AML is a huge and ever-evolving challenge, but for those who embrace it, it becomes a strategic asset—empowering them to navigate the high-stakes financial ecosystem with confidence and poise.
VIP360 is not licensed by FinCEN or any U.S. state regulatory body and does not offer services to U.S. residents or businesses. The insights shared in this blog are for informational purposes only and should not be interpreted as advice or representation of services within the United States.
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