Isle of Man GSC updates AML guidance with focus on B2B and group structures

The island’s regulator wants operators to look at the risks that come through suppliers, partners and corporate groups as well as through players.

The Isle of Man Gambling Supervision Commission (GSC) published updated anti-money laundering guidance for gambling operators on 10 November, asking them to give more weight to risks arising from B2B arrangements, group structures and beneficial ownership.

What has changed in the guidance

Version 1.4 of the AML/CFT guidance for gambling operators reflects the island’s 2025 and 2026 national risk assessments and the threats they identified. It expands on how operators should apply the risk-based approach, including to risks from wider business relationships.

The guidance says:

‘Operators should recognise that risk exposure may arise through the wider business ecosystem in which they operate.’

It asks them to consider how ownership, control, group structures, outsourcing and other significant business relationships affect their risk profile.

Other sections have been refreshed too. They cover business, customer and technology risk assessments, identity checks, customer and enhanced due diligence, payment and transaction risks, terrorist and proliferation financing, sanctions, reporting, staff training and appointments.

The Code itself has not changed

In its notice to operators, the GSC stressed that the underlying requirements of the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 remain the same. The update explains how to meet them.

Operators should review the new guidance ahead of other recent GSC publications, check whether their own frameworks need to change, and make any updates as soon as practicable. Operators that want help can contact the GSC or arrange a drop-in session at its offices in Douglas, where staff will help them.

February’s risk assessment set the agenda

The update follows the island’s money laundering risk assessment for the gambling sector, published in February. It rated the sector as a whole, and online gambling, as medium-high risk, and land-based gambling as medium-low.

Among the main threats it listed were criminal ownership of gambling businesses or B2B services through front companies and complex corporate structures, and organised crime groups, including those from East and Southeast Asia. In Britain, the Gambling Commission raised gambling software to medium risk in its 2026 assessment.

More guidance on the way

In July the GSC stepped up its action against illegal gambling, and on 10 November it also published its 2026 proliferation financing survey. Of operators that also took part in 2024, 94% said they had acted to improve their understanding, and 80% reported better awareness.

Next, the GSC is updating its guidance for software suppliers, for licence holders with network services permissions, and on virtual assets and goods. It has asked operators to suggest areas where they want more detail.

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