There is a wide range of gambling service providers in Ireland, who provide products and services to many different types of customer. The gambling services sector broadly, and Private Members’ Clubs specifically, were analysed in the Money Laundering and Terrorist Financing National Risk Assessment, published in 2016. While the majority of gambling operators are currently unsupervised for AML/CFT purposes, they are otherwise licensed and regulated under the provisions of the Betting Act 1931 (as amended) (‘the Betting Act’) and the Gaming and Lotteries Act 1956, with specific legislation for the National Lottery under the National Lottery Act 2013 and for Totalisator betting under the Totalisator Act 1929, as amended.

While betting/bookmaking (both land-based and online) is the largest sub-sector of the gambling sector, there are a number of smaller scale gambling services available in Ireland which are to be examined in this assessment, namely lotteries, bingo, poker, and gaming and amusement arcades. This assessment will deal with the betting sector first before turning to the smaller sub-sectors. The EU’s supra-national risk assessment deals with all online gambling as one area without distinction between specific activities. Therefore this assessment’s rating of online betting applies to all other online gambling services. The potential vulnerability, risk, and mitigants for each of these areas will be analysed before a residual risk rating is determined.

The focus of this report will be the assessment of primarily money laundering but also terrorist financing risk and potential in the Irish gambling sector. This report takes account of the relevant findings of the EU’s Supra-National Risk Assessment (which was created with input from Irish authorities) which found the specific risk of terrorist financing to be not relevant for its assessment of every gambling sub-sector. Nonetheless, this risk has been taken into account as part of this assessment. It endeavours to expand upon the work done during Ireland’s National Risk Assessment and to determine the appropriate level of AML/CFT requirements to extend to the gambling sector in line with Ireland’s transposition of the EU ‘4th Anti-Money Laundering Directive’.