The Isle of Man Gambling Supervision Commission (GSC) released an updated version of its anti-money laundering guidance for gambling operators on 10 November 2026. The document has been revised to a new version, taking into account the island’s national risk assessments for 2025–2026.
The guidance covers measures to combat money laundering, terrorist financing and proliferation financing (AML/CFT/CPF). The GSC clarified that the core requirements of the Code remain unchanged. The document provides guidance on applying the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019. The updated version provides further detail on risks associated with B2B partnerships, corporate group structures and the identification of ultimate beneficial owners.
Key Changes to the Isle of Man AML/CFT Guidance
According to the GSC, the revision follows the publication of the Isle of Man’s national risk assessments for 2025–2026. The Commission has adapted the guidance to reflect identified threats and common financial crime typologies, while expanding its recommendations on the application of a risk-based approach. Particular attention is now given to assessing business relationships, conducting customer checks and identifying ultimate beneficial owners.
The changes cover several key areas: business risk assessments, customer and technology risk assessments (BRA, CRA and TRA), identity verification, standard and enhanced customer due diligence (CDD and EDD), payment and transaction risks, measures to combat terrorist and proliferation financing, compliance with financial sanctions, and internal and external reporting. The provisions on staff training and the appointment of employees responsible for regulatory compliance have also been updated.
In addition, the GSC has provided more detailed supervisory expectations, updated references to national and international financial crime typologies, and revised the guidance’s diagrams. This version replaces the edition published in June 2025, following the adoption of the Isle of Man’s National Risk Appetite Statement on eGaming. The original version of the guidance was published in December 2020.
GSC Recommendations for Operators
The Commission urged gambling companies to review the updated guidance and other recently published materials, and then assess whether their existing frameworks for preventing money laundering, terrorist financing and proliferation financing (AML/CFT/CPF) are consistent with the new recommendations. Where shortcomings are identified, operators should make the necessary changes as soon as practicable, the GSC said.
Companies seeking further clarification can contact their usual representatives at the Commission or arrange an in-person consultation at its offices in Douglas.
Regulator’s Plans
The GSC’s work to update its regulatory guidance is ongoing. In particular, the Commission intends to revise documents for software suppliers, holders of licences under the Online Gambling Regulation Act (OGRA) with network services permissions, and companies dealing in virtual assets and virtual goods.
The GSC has also invited industry participants to suggest topics on which further guidance is needed. Operators can send their proposals to the Commission’s AML/CFT inspections team at gscamlinspections@gov.im.
The updated guidance marks another step in the Isle of Man’s legislative changes, following Tynwald’s approval of a new Gambling bill in May and the passage of the Data Assets Act in April.
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