The overall medium-high risk rating for the RITA sector reflects its size, ease of access and demographic spread coupled with its higher risk products and services. The gambling and betting sector is recognised as being vulnerable to a number of high-risk ML/TF activities and industry specific risk factors.

Given the size, nature and diversity of this sector and its previous and continued unregulated nature, it is difficult to get an accurate picture of the nature and extent of ML/TF. However, based on domestic and international evidence, HVDs are highly vulnerable to ML/TF. Coupled with low overall ML/ TF awareness and lower levels of supervision and reporting obligations, the HVD sector presents a medium-high inherent risk of ML/TF.

Both domestic and international evidence and guidance highlight the significant ML/TF risks presented by the TCSP sector. The high-risk services/products of this sector combined with ease of access, wide geographic spread, high-risk customers and the ability to disguise and conceal beneficial ownership makes this an inherently high- risk sector.