The Irish government has published a national risk assessment on financial crime and handed the Gambling Regulatory Authority of Ireland (GRAI) a mandate to supervise the industry more strictly.
The new initiative and 30-point action plan addresses a multitude of sectors in which financial crime is seen as a present threat.
Led by Tánaiste and Minister for Finance Simon Harris, along with the Minister for Justice, Home Affairs and Migration Jim O’Callaghan, various categories of gambling service providers have been assigned new risk levels.
In an upgrade from 2018/19 risk ratings, remote bookmakers are now seen as carrying a ‘significant’ risk of money laundering. Private members’ gambling clubs are the only other type of provider to move onto this high-alert footing.
Harris commented on the need for refreshed risk classification, saying: “Criminals are becoming increasingly sophisticated, exploiting technology, operating across borders and adapting rapidly to change. Government cannot stand still in the face of these threats.”
The action plan
In accordance with this re-assessment of financial crime within the gambling industry, the GRAI is being granted new powers and given fresh restrictions to implement.
Private members’ clubs will be made subject to mandatory licensing requirements, bringing them in line with the rest of the industry and facilitating more regulatory oversight.
Traditionally these operations wouldn’t fall under the Gaming and Lotteries Act of 1956 and have not been considered gambling services.
Casinos offering machine-based gambling are also to be governed with a shortler leash – though the action plan doesn’t outline specifics, it explains that there will be “stricter enforcement of licence conditions and anti-money laundering obligations.”
Increased use of cryptocurrency is a key driver of the government’s new overall direction, and as a preventative measure, the GRAI will be responsible for establishing an industry standard of due diligence on crypto as a source of betting funds.
The other point for the attention of the GRAI is around payments – operators will now have to manage payments via a ‘closed-loop’ system, meaning deposits and withdrawals must be made from and to the same account.
O’Callaghan says the action plan “provides a practical roadmap for keeping Ireland’s response effective, proportionate and fit for purpose.”
Vulnerabilities
These measures are primarily framed as preventative, with a number of key vulnerabilities of the gambling sector identified in the risk assessment.
Cash-based gambling poses an issue due to the lower degree of transparency that comes with cash transactions.
The government’s view is that this susceptibility to money laundering increases the risk of land-based operations being run by criminal enterprises.
On the other side of the coin, online platforms are also classed as a money-laundering risk due to the sheer volume of digital transactions.
Data from 2023 shows that the two industries were, at least at the time, comparably sized in Ireland, with retail bookies generating around €2.4bn in revenue and online platforms drawing approximately €2.6bn.
Notably, due to the lack of regulatory framework around private members’ clubs, there is no equivalent data in this area.
Cross-departmental collaboration
O’Callaghan added: “Implementation of the Action Plan will involve close cooperation between government departments, An Garda Síochána, Revenue, the Central Bank, regulators and other stakeholders.”
And while the published plan identifies the Criminal Justice Act of 2010 as the primary legislation governing anti-money laundering (AML) obligations, it also acknowledges that reforms of the licensing and supervisory framework are still in the pipeline.
Where now the different categories of gambling services are supervised by a patchwork of different agencies, the GRAI, established in March 2025, will eventually be installed as the competent authority for all of these categories.
The consolidation of this framework is still being prepared via a process of public consultation and draft regulations off the back of the 2024 Gambling Regulation Act.
On the future of financial crime monitoring, O’Callaghan ended his statement by saying: “The government will continue to monitor emerging risks and update its response as necessary to ensure Ireland remains resilient in the face of a rapidly evolving threat environment.”
