Isle of Man regulator updates AML guidance for online and B2B firms
Licence holders must prioritise reviewing their compliance systems following recent risk assessments highlighting digital betting vulnerabilities.
Key takeaways
- The Isle of Man Gambling Supervision Commission (GSC) has published revised supervisory guidance on money laundering, terrorist financing, and proliferation financing.
- Online gambling and B2B software vendors face heightened scrutiny following a February 2026 assessment that rated the wider betting sector as medium-high risk.
- Core legal requirements under the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 remain unchanged.
- Further targeted guidance is being drafted for software suppliers, virtual asset businesses, and Online Gambling Regulation Act (OGRA) network service licence holders.
- A 2026 GSC survey found that 94 per cent of repeat respondents and 85 per cent of first-time respondents took action to improve proliferation financing awareness.
TL;DR: The Isle of Man Gambling Supervision Commission (GSC) has issued revised supervisory guidance, instructing licence holders to evaluate their financial crime controls against threats in online betting and business-to-business (B2B) partnerships. Released following the jurisdiction’s 2025 and 2026 National Risk Assessments, the updated framework clarifies regulatory expectations for customer due diligence, transaction surveillance, and risk evaluations. Operators have been told to treat the review of these updated guidelines as a priority to ensure their anti-money laundering and counter-terrorism financing systems remain robust.
UK.- Gambling operators on the Isle of Man have been instructed to evaluate their financial crime safeguards after the territory’s regulator published its revised supervisory guidance to respond to potential threats identified within digital betting and business-to-business (B2B) partnerships. The Isle of Man Gambling Supervision Commission (GSC) issued the updated framework following the jurisdiction’s 2025 and 2026 National Risk Assessments, which analysed vulnerabilities linked to money laundering, terrorist financing, and proliferation financing.
Licence holders are now expected to determine whether their current anti-money laundering, countering the financing of terrorism, and countering proliferation financing (AML/CFT/CPF) controls are sufficient to mitigate these evolving dangers. This regulatory push builds upon the February 2026 Gambling Sector Money Laundering Risk Assessment, a report that designated the island’s betting sector as carrying a medium-high risk profile for illicit finance. Within that evaluation, digital gaming was identified as a primary point of vulnerability due to high payment volumes, cross-border fund flows, remote onboarding, and diverse payment options. Conversely, physical, land-based venues, which cater mostly to local clientele, were given a medium-low risk rating.
Findings from the February 2026 review also highlighted growing threats to online platforms and B2B software vendors from organised crime syndicates, notably groups based in East and Southeast Asia. Investigators noted that international transfers, complex corporate ownership structures, and restricted oversight of the entities and individuals utilising gaming software create blind spots that hinder both source-of-funds verification and the flagging of suspicious activity.
The regulator said the updated text provides clearer expectations around risk evaluations for businesses, clients, and technologies, alongside protocols for identity checks, standard customer due diligence, heightened scrutiny for elevated-risk profiles, and transaction surveillance. Additional amendments cover compliance with financial sanctions, terrorist and proliferation financing safeguards, internal and external suspicious activity reporting, employee training, and key compliance appointments. The commission has also refreshed the document’s visual diagrams, formatting, and citations regarding domestic and global standards, crime typologies, and reference materials.
The core legal obligations set out in the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 have not been altered. Nevertheless, firms have been told to review the new guidance as a priority and to roll out any required updates to their compliance systems as quickly as possible. Industry stakeholders wishing to suggest topics for future clarification can email [email protected].
Looking ahead, the commission is drafting further targeted guidance for software providers, businesses holding Online Gambling Regulation Act (OGRA) licences with network services permissions, and firms dealing in virtual assets and goods, extending to technology vendors that do not interact directly with end-users.
Meanwhile, the GSC’s 2026 Proliferation Financing (PF) Operator Training and Awareness Survey shows a clear improvement in PF awareness across the gambling sector since the first survey was undertaken in 2024. The survey found that PF awareness and integration into operators’ frameworks had improved since 2024 in that 94 per cent of repeat respondents and 85 per cent of first-time respondents reported taking action to strengthen understanding.
Among repeat respondents, 80 per cent reported improved awareness while the remaining 20 per cent said awareness was already high. Training was found to be broadly established – generally annual and tailored to operators’ risks. Combined ML, TF and PF training remains appropriate where each risk is clearly addressed, the GSC said.
While the survey findings reflect operators’ self-assessments, they will inform the GSC’s future outreach. The regulator said it will use the findings to inform outreach and test effectiveness in practice.
FAQs
Why has the Isle of Man GSC updated its AML guidance? The regulator updated its guidance following the 2025 and 2026 National Risk Assessments and a February 2026 sector assessment. These reviews identified heightened financial crime vulnerabilities in digital gambling and B2B partnerships, particularly involving cross-border fund flows, complex ownership structures, and threats from organised crime syndicates in East and Southeast Asia.
Have the legal requirements under the Isle of Man AML Code changed? No, the core legal obligations set out in the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 remain unaltered. However, operators must review the updated guidance as a priority to ensure their existing compliance systems meet the regulator’s clarified expectations for due diligence, reporting, and risk assessments.
Which gambling sectors face the highest risk according to the GSC? The February 2026 assessment designated the overall Isle of Man betting sector as carrying a medium-high risk profile, with online gaming and B2B software suppliers identified as primary points of vulnerability. In contrast, physical, land-based gambling venues serving mainly local customers were given a medium-low risk rating.
What future regulatory guidance is the Isle of Man GSC preparing? The commission is currently drafting targeted guidance for software providers, businesses holding Online Gambling Regulation Act (OGRA) licences with network services permissions, and companies dealing in virtual assets and goods. This upcoming framework will also extend to technology vendors that do not interact directly with end-users.
