Ireland Adds Gambling to Its National Risk Assessment, Flags Remote Bookmakers and Private Clubs

Ireland has folded gambling into a new national risk assessment, backed by a 30-point action plan and led by the Gambling Regulatory Authority of Ireland (GRAI). For PSPs and acquirers serving the market, the practical message is simple: more scrutiny on cash, crypto, remote betting, and payment flows that are easy to move across borders and hard to explain after the fact.

1. The new strategy treats remote bookmakers as carrying a significant risk of money laundering, alongside private members’ clubs, which will be assessed at the same risk level. The government also said those clubs will now be licensed, closing a gap that had left much of that activity outside formal gambling law.
2. Cash is a major focus of the assessment because it is difficult to trace. Officials said land-based venues are especially exposed where there is heavy cash play, while online platforms face their own issues because of the volume and velocity of digital transfers and the use of modern payment methods.
3. The plan also puts cryptocurrency on the radar. The GRAI is expected to introduce industry-wide standards for digital assets, and operators will be required to adopt “closed-loop” payment systems, meaning customers must withdraw funds to the same account they used to deposit.
4. The action plan is built around coordination between law enforcement, tax authorities, and financial regulators, with GRAI expected to take a more active supervisory role. The longer-term aim is to replace Ireland’s fragmented setup with a single regulator under GRAI.
5. Finance Minister Simon Harris said criminals are “becoming increasingly sophisticated,” using technology, operating across borders, and adapting quickly; Justice Minister Jim O’Callaghan said the government will keep updating its response as threats evolve. The new risk assessment follows Ireland’s earlier gambling reforms and the rollout of a tougher regulatory structure this year.

For high-risk payment providers, the detail that matters is not the rhetoric about “oversight” but the operating constraint: Ireland is now explicitly mapping gambling risk to traceability, account matching, and supervisory coordination. That usually means more pressure on onboarding, source-of-funds controls, transaction monitoring, and any product that makes cash-in, cash-out, or cross-border movement look too easy.