Africa’s rapidly expanding gambling industry is facing a significant regulatory challenge of safeguarding a legitimate, increasingly digital sector from money laundering while maintaining oversight of players and transactions.
This concern was emphasised during a high-level panel discussion on anti-money laundering (AML), illicit financial flows and regulatory responsibility in Africa’s gaming sector, this week, where experts cautioned that while the risks to the industry are substantial, equating gambling with money laundering is not an effective approach.
Dr Constance Gikonyo, an Advocate of the High Court of Kenya and a Senior Lecturer at the University of Nairobi, said the gambling sector should be regarded as one of the areas requiring serious AML attention, particularly as technology has transformed the industry from predominantly physical betting into an increasingly digital and cross-border business.
Peter Emolemo Kesitilwe, Chief Executive Officer of the Africa iGaming Alliance, cautioned against characterising the entire industry as a vehicle for financial crime.
“I do not believe that the risk associated with the gaming sector is exaggerated.”
She noted that the expansion of online gambling has heightened potential exposure, as transactions now move rapidly through multiple digital channels.
Peter Emolemo Kesitilwe, Chief Executive Officer of the Africa iGaming Alliance, cautioned against characterising the entire industry as a vehicle for financial crime.
He stated, “The industry is sometimes unfairly treated as though gambling itself is synonymous with money laundering.”
He argued that a well-regulated digital gambling environment can offer regulators substantial visibility into financial activities through customer identification, payment records, IP and device information, wagering histories, and records of deposits and withdrawals. These he said, collectively create a comprehensive digital trail that can help identify suspicious behavior.
However, the responsibility rests primarily with operators to utilise these systems effectively.
Operators are required to conduct thorough customer due diligence, understand the sources and movements of funds, identify unusual transactions, and submit meaningful suspicious transaction reports, ensuring that commercial interests do not supersede AML obligations.
Kesitilwe emphasised the importance of holding licensed operators to high standards while designing regulations that retain legitimate players and transactions within regulated markets.
But Kesitilwe said regulators must also consider what happens when legitimate gambling activity is pushed outside the regulated market.
“If players migrate offshore, gambling does not necessarily cease. What may disappear is regulatory visibility.”
Kesitilwe, who was previously involved in the regulatory side of Botswana’s gambling sector, said he supported the reforms but cautioned that policymakers must consider the consequences of regulatory and fiscal decisions on where players ultimately transact.
That warning has particular resonance in Botswana, where there is growing public discussion about whether some Batswana’s gambling activity may have migrated to offshore platforms, while the country undertakes reforms to its gambling legislation.
Kesitilwe, who was previously involved in the regulatory side of Botswana’s gambling sector, said he supported the reforms but cautioned that policymakers must consider the consequences of regulatory and fiscal decisions on where players ultimately transact.
Some lessons can be seen across the continent. Ethiopia provides one of the most dramatic recent examples, where in December 2025, the Ethiopian Lottery Service revoked the operating licences of sports betting companies, effectively shutting down licensed sports betting operations.
Zambia, meanwhile, has undergone significant changes to its betting tax framework. Its 2025 Betting Act introduced a betting levy and requirements for operators to maintain electronic records of deposits and withdrawals, while parliamentary committees raised concerns about taxation measures potentially undermining the sustainability of the regulated market.
For Kesitilwe, these experiences demonstrate why regulation cannot be designed only around what happens inside a licensed operator.
This warning has implications that extend beyond individual gambling companies.
Africa’s gambling industry increasingly operates across borders, with technology, payment platforms, customers, and operators frequently situated in different jurisdictions.
However, African countries maintain significantly different licensing regimes, know-your-customer requirements, definitions of reportable activity, payment rules, tax structures, and supervisory capabilities. This fragmentation creates regulatory gaps that sophisticated criminals can exploit.
“Criminal money looks for those regulatory seams,” said Kesitilwe.
A single transaction may involve a customer in one country, technology hosted in another, an intermediary payment platform in a third location, and an operator licensed in a fourth jurisdiction.
For regulators acting independently, obtaining a comprehensive view of the entire transaction can be extremely challenging.
Gikonyo argued that effective solutions require regulators and industry stakeholders to collaborate rather than operate in isolation.
A gambling transaction may involve a betting operator, bank, mobile-money provider, and telecommunications company, each regulated by a different authority. She stated, “without them speaking to each other, that definitely will create a problem.”
The panel advocated for enhanced regulatory cooperation and interoperability across Africa, particularly concerning beneficial ownership, customer identification, licensing, AML standards, regulatory intelligence, and information sharing.
The panel advocated for enhanced regulatory cooperation and interoperability across Africa, particularly concerning beneficial ownership, customer identification, licensing, AML standards, regulatory intelligence, and information sharing.
Importantly, the experts noted that harmonization does not require identical gambling laws across Africa. Rather, it necessitates compatible supervisory outcomes.
This distinction may become increasingly significant as digital gambling continues to expand across the continent.
Policymakers therefore face a dual challenge: protecting the integrity of the financial system while ensuring that regulation does not drive legitimate economic activity underground.
For the gambling industry, operators must prioritize AML obligations, invest in technology and compliance, and demonstrate that growth can be achieved alongside responsible governance.
For regulators, the challenge is to develop systems that enable information to move as rapidly as financial transactions, since in a digital, cross-border gambling economy, the weakest regulatory link may present the greatest opportunity for financial crime.
Experts cautioned that fragmented or excessively restrictive regulation can generate unintended risks.
