UKGC Open Banking Study Highlights Challenges in Tracing Illegal Gambling Payments

Summary

The Gambling Commission published new research on 28 October 2026 examining illegal gambling through anonymised Open Banking records linked to survey information.

The study provides directly observed transaction evidence. It introduces no new regulatory requirements and cannot establish the size of Great Britain’s illegal gambling market.

What changed

The Commission tested different methods of identifying illegal gambling payments:

• Matching known operator names against transaction descriptions failed.

• Matching previously identified payment descriptions and suspected merchant names produced 3,426 unique transactions involving 179 individuals.

• The analysis used records from approximately 38,000 people, covering July 2018 to July 2026.

The findings have substantial limitations. The sample is not nationally representative, cryptocurrency payments are excluded, and unidentified illegal transactions may remain in the dataset. The method also depends on prior identification of operators and cannot independently discover previously unknown illegal businesses.

Who is affected

The findings are relevant to regulators developing illegal-market intelligence, banks and PSPs assessing payment visibility, and operators and technology suppliers evaluating monitoring capabilities.

Our Take

The practical issue is the connection between a gambling website and the identity appearing in payment records. A monitoring system built around brand names alone may miss transactions where the payment descriptor provides no recognisable link to the operator. Effective enforcement therefore requires evidence connecting websites, merchants and payment routes.

This supports combining digital monitoring with payment intelligence. Each source answers a different question: whether an operator targets a market, how customers reach it, and how funds move. Reliable links between those layers can help authorities act against illegal supply and protect the regulated market.

The limits matter equally. Detected transactions are evidence of activity, not a measure of total market share. Regulators and industry should resist turning incomplete payment visibility into precise estimates of illegal gambling.