The Gambling Commission says society lotteries are low risk. Don’t use that as an excuse to do nothing.

The Gambling Commission has published its 2026 assessment of money laundering and terrorist financing risks in British gambling. The good news for society lotteries and external lottery managers is that the overall rating remains low risk.

That is sensible. Society lotteries are not casinos. Most are raising money for worthwhile causes through relatively straightforward products, modest ticket prices and well-established player bases.

But here is the important bit: low risk does not mean no risk.

It certainly does not mean you can leave an old risk assessment untouched for three years, assume your external lottery manager has everything covered, or wait until something goes wrong before asking how payments, prizes and player accounts are being monitored.

The Commission’s latest assessment is a useful prompt to check that the basics are actually working.

“We’re low risk” is not a compliance plan

I have seen plenty of lottery risk assessments that are technically present but practically poor. They are often generic, full of vague statements and filed away after being approved. Nobody refers to them when a the LCCP is updated, a supplier changes, or an odd pattern of transactions appears.

A good risk assessment does not need to be 40 pages long. It does need to reflect the way your lottery operates today.

If you sell online, take recurring payments, use retail partners, work with an ELM, run promotions, offer bigger prizes or have recently changed systems, then your risk profile may have changed too. The document must keep up.

The question I would ask is simple:

If the Gambling Commission asked why you consider a particular risk low, could you explain your reasoning and show what you do about it? Have you thought about it, and can you provide evidence to support your stance?

If the answer is “I think our supplier handles that”, or you’ve not reviewed it recently, it is probably time for a closer look.

A real weak spot: people and training

One of the more striking parts of the Commission’s new assessment is the addition as ‘New risk‘ of a lack of competence of key personnel and licence holders, which it says can be exploited by criminals seeking to launder the proceeds of crime. It also flags that training for staff is insufficient and not appropriately tailored.

For society lottery operators, that is the bit to pay attention to!

It is easy to assume that because lotteries are generally low risk, the people running them do not need the same level of attention as higher-risk gambling sectors. That is exactly the wrong lesson to take from the report. A low-risk product still needs knowledgeable people behind it – the controls are only as good as the people applying them.

In practice, this is where I see weakness most often. Training is too infrequent, too old, or too detached from what staff actually do day to day.

People may think they know the rules in theory, but drift is gradual and it’s easy to become complacent, because “We’ve never had any problems before”

For society lotteries, that matters. You need staff who can recognise when something does not look right, understand when to escalate it, and know what action to take.

This is also a good moment to ask whether your key people are genuinely competent in the areas that matter most: risk assessment, customer due diligence, unusual transaction monitoring, record keeping and escalation. If they are not, it’s a bit of a ticking timebomb!

And that is why tailored training is so important. Not training for the sake of training, but training that reflects the actual risks in a society lottery operation and gives staff the confidence to deal with them properly and raise issues before they become a problem.

If you use an ELM, make sure you are receiving real assurance

The Commission assesses ELMs separately in this year’s report. That is a timely reminder that outsourcing lottery management does not remove the society’s responsibilities.

An ELM may run the website, manage payments, speak to players, issue prizes and produce reports. That can work extremely well. But the society should still understand what is happening and be able to challenge where necessary.

A quarterly meeting that focuses entirely on ticket sales and campaign performance is not enough. Ask about unusual activity, fraud attempts, payment anomalies, customer complaints, refunds and prize-payment checks. Ask what gets escalated, who decides what to do, and when the society will be told.

Most importantly, make sure the answers are not just reassuring — make sure they are evidenced.

The biggest weakness is often not the control. It is the lack of ownership.

In many organisations, the problem is not that nobody cares. It is that everybody assumes somebody else is responsible.

The lottery manager thinks your finance team monitors payments. Finance assumes the ELM does it. You think they both do. But do they?

The ELM may have systems in place, but has no clear instruction on what must be reported to the society. Trustees receive an annual compliance update but have little opportunity to ask useful questions.

That is how gaps appear.

Every lottery should have clear ownership for its risk assessment, supplier oversight, staff awareness and escalation routes. Staff do not need to be financial-crime experts, but they should know that something unusual should be reported rather than ignored.

And trustees or senior managers should receive enough information to be confident that the lottery is properly controlled — not just that it is performing well commercially.

A sensible time for a quick health check

The Commission is not saying that society lotteries are a major target for money laundering. It is saying that the sector is low risk overall, while recognising that weak operator controls can still have a meaningful impact.

That is a fair assessment.

So, before this becomes another report that gets circulated, noted and forgotten, take an hour to ask a few honest questions. Is your risk assessment current? Do you understand your payment routes? Are your ELM reporting arrangements meaningful? Do staff know what to do if something does not look right?

If not, this is the ideal time to put it right.

Lottery Advisory helps society lotteries review their governance, compliance arrangements and ELM oversight in a practical, proportionate way. If you would like an independent view of your current arrangements, get in touch.