The Isle of Man Government has published its national risk assessment of the Insurance sector. This assessment of the insurance sector’s exposure to money laundering risk, covering life and non-life (captive, commercial and general insurance intermediation) builds upon the 2020 Money Laundering / Terrorist Financing National Risk Assessment (NRA).
Although this document does not directly assess the Gambling sector, various emerging risks remain relevant for GSC Operators, including:
· Complex structures & shell companies;
· Use of Virtual Assets in ML;
· Wealth generated from ‘unconventional’ channels (eg. influencers, gamers) which challenges traditional due diligence mechanisms;
· Artificial Intelligence & other technologies are evolving rapidly.
These inherent risks and vulnerabilities can be exploited by criminals disguising/settling large amounts of funds (including through identity theft), persons trying to evade/avoid tax, sanctioned persons and those trying to hide or disguise beneficial ownership (e.g. using intermediaries).
Typologies/flags play a vital role in strengthening detection and prevention efforts by highlighting how criminals exploit systems to launder illicit proceeds, finance terrorism, and support proliferation activities. The GSC recommends Operators familiarise themselves with the island's NRA documents and, where appropriate, use them to inform their own business risk frameworks.
You can view all Isle of Man National Risk Assessment documents on the Countering Financial Crime website.