New strategy sets out a clear compliance roadmap for gambling operators
Ireland is preparing for a significant tightening of anti-money laundering controls across the gambling sector, with crypto payments and customer withdrawals emerging as two of the main areas of focus.
The country’s first National Anti-Money Laundering, Countering Financing of Terrorism and Countering Proliferation Financing Strategy, launched on 13 August by Tánaiste and Minister for Finance Simon Harris, formally identifies gambling as a sector requiring stronger oversight.
While Irish gambling operators have been subject to AML obligations since 2018, the new strategy represents the first time gambling has been placed within a dedicated national AML policy framework.
Four measures set for 2027
The practical implications for operators are detailed in the Strategy’s Priority Actions Implementation Plan. Four measures specifically target gambling, with all four assigned to the Gambling Regulatory Authority of Ireland (GRAI) and scheduled for delivery by the second quarter of 2027.
The measures include bringing machine-based casino clubs under a stronger regulatory regime, introducing mandatory licensing for private members’ clubs providing gambling services, establishing industry guidance on crypto as a source of funds, and requiring gambling operators to adopt closed-loop payment systems.
The latter could have the most immediate operational impact.
Under a closed-loop model, customers would generally receive withdrawals through the same payment account used to make their deposits. The objective is straightforward: keeping the flow of funds traceable from the original payment through to the eventual withdrawal.
For operators, however, the change could require adjustments to payment infrastructure and customer processes, particularly where a card, bank account or digital wallet used for a deposit is no longer available when a withdrawal is requested.
Crypto deposits face closer scrutiny
Crypto is another central element of Ireland’s new AML approach.
The implementation plan calls for an industry-wide standard governing the acceptance of crypto-related activity as a source of funds. Operators will be expected to carry out appropriate due diligence and establish that crypto-derived funds are legitimate.
This does not create the underlying source-of-funds obligation from scratch. Irish gambling businesses are already required to conduct customer due diligence when payments to or from a gambling service provider reach €2,000 in aggregate, including establishing the source of funds.
The new measure is instead intended to create a consistent framework for applying those requirements to cryptocurrency-related deposits.
At the wider European level, Ireland is also preparing for the EU’s new AML framework. From 10 July 2027, much of the existing national AML regime will be replaced by directly applicable EU rules.
The national strategy also incorporates requirements concerning crypto-asset transfers under the EU Transfer of Funds Regulation, including the so-called Travel Rule, which requires information about the originator and beneficiary to accompany transfers. Additional safeguards will apply to transactions involving private crypto wallets and crypto firms located outside the EU.
GRAI set to take a bigger AML role
The decision to place all four gambling actions under the GRAI is particularly significant.
Gambling operators are already designated persons under Ireland’s Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. They must therefore carry out customer due diligence, monitor transactions and report suspicious activity.
For now, AML supervision remains with the Department of Justice, Home Affairs and Migration’s Anti-Money Laundering Compliance Unit.
That arrangement is expected to change.
Section 230 of the Gambling Regulation Act 2024 provides for AML supervision to move to the GRAI. Although legislation surrounding the new gambling regulator came into effect in February 2026, Section 230 was specifically excluded from that commencement order.
The new implementation timetable points towards the transfer taking place alongside the wider reforms in 2027.
A separate action in the national plan also calls for AML and counter-terrorist financing supervisors to receive stronger financial enforcement powers by Q2 2027. The GRAI already has substantial sanctioning powers under the Gambling Regulation Act, including the ability to impose fines of up to €20 million or 10% of turnover, whichever is higher.
A wider European compliance shift
Ireland’s move comes as European gambling operators face a broader overhaul of AML requirements.
The EU’s new anti-money laundering package is set to introduce a more harmonised regulatory framework across member states, reducing the reliance on individual national AML regimes.
For Irish operators, this means the next 12 months are likely to be particularly important for compliance planning.
Payment flows, cryptocurrency deposits, source-of-funds procedures, customer due diligence and the licensing status of gambling clubs will all come under closer scrutiny as the 2027 deadlines approach.
FATF review adds pressure to deliver
There is also an international deadline in the background.
Ireland is due to undergo its next Financial Action Task Force (FATF) Mutual Evaluation in 2028. The government’s implementation plan is designed to provide measurable evidence of progress before that assessment.
That makes the Q2 2027 deadlines more significant than a routine legislative timetable. The gambling measures have named ownership, defined objectives and a specific delivery date, suggesting operators should expect them to translate into concrete regulatory requirements rather than remain policy commitments.
For Ireland’s gambling industry, the message is becoming increasingly clear: AML compliance is moving from a largely established obligation into a much more closely supervised area of regulation, with payment transparency and crypto-related funds firmly at the centre of the next phase.
Source: European Gaming