One money laundering typology identified internationally involves making deposits with a gambling operator and subsequently either not using gambling services at all or using them only to a very limited extent, for example by placing low-value, low-risk bets. The funds are then withdrawn from the gambling operator's systems after a short period of time (the so-called cash-in, cash-out method). This activity allows individuals to claim that the origin of the funds is related to gambling activities, as the payout is made by a gambling operator. Through this new typology report, the Financial Intelligence Unit encourages the increased identification and reporting of such activities.
In addition to potential schemes, the Financial Intelligence Unit's typology report outlines risk indicators that, when considered together with other circumstances, may point to suspicious activity. Where the activity patterns and risk indicators described in the typology report are identified, service providers should consider applying enhanced due diligence measures. If suspicion remains, a report must be submitted to the Financial Intelligence Unit, with reference to Typology 10TT202607.
According to Estonia's National Risk Assessment, the gambling sector is exposed to a higher-than-average level of money laundering risk. Contributing factors include online remote gambling, including customers from jurisdictions that may present very high money laundering risks, the use of cryptocurrencies for placing bets or withdrawing winnings, and foreign or foreign-linked service providers whose activities are difficult to supervise effectively.
As in the rest of Europe, growth in Estonia's gambling market has been driven primarily by online casinos. The number of service providers doubled within four years, reaching 58 operating licences by the end of 2025. Of the 45 companies actively providing gambling services, 17 operators submitted reports to the Financial Intelligence Unit last year. Notably, three Estonian companies accounted for 93% of all reports submitted.
