UK Gambling Commission reviews unlicensed gambling activity using bank data

The UK Gambling Commission (UKGC) has published an analysis of anonymised banking records that looks at how payments linked to unlicensed gambling operators can show up alongside activity with licensed businesses. The point for PSPs is not that the report sizes the illegal market — it does not — but that the same customer can sit in both buckets at once.

1. Published on 28 October 2026, the report uses open banking information from 38,000 consenting individuals collected between July 2018 and July 2026. YouGov gathered the records and supplied them in anonymised form, and the UKGC linked the transaction data with other YouGov survey information, including Problem Gambling Severity Index (PGSI) scores where available.
2. The Commission’s central finding is straightforward: detected payments involving unlicensed operators did not coincide with a sustained move away from licensed gambling. In other words, some people in the sample made payments to both types of operator, so activity in the unlicensed market can occur alongside the use of licensed providers rather than replacing it.
3. To identify suspected unlicensed payments, the regulator used several filters. A first pass looking for known operator names in transaction descriptions with fuzzy matching found nothing. A second comparison against bank-statement descriptions known to involve illegal gambling operators identified 821 transactions, and a further merchant-name check added 2,628 more records. Twenty-three transactions appeared in both exercises, leaving 3,426 unique transactions linked to 179 individuals.
4. The broader dataset contained 4.8 million transactions with licensed non-lottery gambling companies and 157.2 million transactions overall. The method depended on descriptions and merchant names already associated with known or suspected operators, so it was not built to find every unlicensed business or every payment made to one. The findings also do not establish the legal position of every merchant record.
5. The overlap matters operationally: the UKGC examined 122 people who had at least two detected unlicensed transactions, and 91% of them also had transactions with licensed gambling operators. The analysis did not show a substantial sustained fall in licensed-operator transactions after a person’s first detected payment to an unlicensed operator, which means payment monitoring will not always produce a clean either/or picture.

The report is a useful reminder for high-risk PSPs and acquirers that transaction screening against known descriptors can catch part of the picture, but not all of it. The UKGC’s sample is non-representative, and the study does not estimate the size of the illegal gambling market or prove harm — but it does show that licensed and unlicensed activity can sit in the same customer history, which is exactly the kind of overlap compliance teams have to sort out in practice.