Ireland has placed remote bookmakers in a higher money laundering risk category as part of its latest national financial crime review. The change marks a clear shift from the 2018/19 assessment, when the sector carried a lower risk profile.
Private members’ clubs are also treated as a significant ML risk. That is mainly because of cash-heavy casino-style activity and weaker AML controls in parts of the segment.
The timing is crucial for operators. Right now, the country is moving from a fragmented model toward consolidated supervision under the Gambling Regulatory Authority of Ireland (GRAI). AMLCU remains the competent authority during the transition
Private Clubs Face a Licensing Gap Closure
The strategy is also targeting private members’ clubs. These have been treated as a grey area in terms of gambling regulation in Ireland for quite a long time. Such venues have not been regulated the same way as mainstream gambling businesses under the older regulatory framework.
In its turn, the government aims to license and regulate such clubs in a mandatory way. This way, it would be easier to analyze ownership, governance, customer activity, and AML controls.
Venues with gaming machines are also coming under additional scrutiny. The action plan points to stricter enforcement of licence conditions and AML obligations. The practical detail still needs to be set out through rules and supervision.
Payments and Crypto Checks Get Sharper
The other pressure point is payments. Operators will be required to adopt a closed-loop payment model. Under the plan, customer withdrawals must be paid to the same payment account used to make the deposit. This is supposed to reduce the space for third-party movement of money through gambling accounts.
Cryptocurrencies have been identified as emerging risk areas. The GRAI is expected to help set a clearer due diligence standard for crypto used as a source of gambling funds. The effect might be seen in onboarding checks, source-of-funds reviews, and how operators document unusual activity.
The report has also highlighted the differences in risks between retail and online gambling. Cash-based gambling poses the risk of poor visibility in transactions. The risk for online gambling arises because of the high volume and speed of transactions. In 2023, retail bookmakers generated €2.4bn, while online platforms recorded revenues of €2.6bn.
GRAI Moves Toward a Wider Supervisory Role
Ireland’s current AML supervision of gambling is split across various organizations. In the long run, more powers are going to be delegated to the GRAI as the competent authority for gambling services.
The next stage depends on the implementation of the Gambling Regulation Act 2024, draft regulations, and public consultations. As of now, operators should treat the action plan as an early signal of where Irish enforcement is heading.
Ireland is no longer treating gambling reform as only a licensing issue. AML controls, payment traceability, and crypto checks are becoming part of the same regulatory test. Operators with weak documentation may feel the change first, even before the new framework is fully settled.
