AML/CFT Compliance Inspections

As the Island's gambling regulator, the GSC is responsible for regulatory oversight of the gambling sector including operators’ compliance with legislation such as the Gambling Acts and the Gambling (Anti- Money Laundering and Countering the Financing of Terrorism) Code 2019 (the AML/CFT Code).

The GSC supervises compliance through a combination of self-assessments and on-site reviews. Desk-based reviews of self-assessments and any documents provided allow the GSC to assess an operator’s policy and process. On-site activities include attending operators’ premises, customer sampling and face-to-face meetings.

On-site inspections may be standalone or a combined AML/CFT and General Compliance inspections depending on the risk assessment of the operator, the time since the latest AML/CFT or General Compliance inspection, the next scheduled inspection, and the availability of the GSC’s Officers.

What do we assess on an inspection?

AML/CFT Supervision forms a crucial part of the GSC compliance programme.

Ongoing supervision entails a number of checks to ensure operator’s compliance with IOM legislation and regulations.

Inspections comprise of pre-inspection checks, self-assessments, onsite inspections and post-inspection sampling.

A full AML/CFT inspection will include analysis on all areas of the AML/CFT Code 2019, whilst a targeted inspection will comprise of an inspection on a focused area.

Both a full and targeted inspection will include onsite attendance by the AML/CFT Inspections Team at the operator’s registered address.

The GSC’s approach to AML/CFT Failings

The GSC seeks to be satisfied that issues that pose a risk to the public and the Island’s reputation are given appropriate attention and that such issues are dealt with promptly. Wherever appropriate, the GSC will work with the sector through its normal supervisory processes to address any failings identified. 

The GSC takes a staged approach to AML/CFT failings:

Stage 1 - Typically, a report resulting from a supervisory inspection will include actions and deadlines to address any identified areas of weakness or contravention of the AML/CFT legislation.

Stage 2 - The GSC will then work with the subject to ensure that actions are completed.

Stage 3 - Where the GSC has particular concerns in relation to AML/CFT compliance (whether identified through an inspection or not), the matter will be referred to the GSC’s Enforcement Team for consideration of further action.

You can email any questions you have to our team at