10 November 2026: GSC Release Updated AML/CFT/CPF Guidance for Gambling Operators

Please be aware that the Isle of Man Gambling Supervision Commission has now released updated  AML/CFT guidance for gambling operators. The update follows the 2025/2026 suite of National Risk Assessment (NRA) documents released earlier this year.

So, what’s changed?

The guidance has been updated to reflect 2025/2026 National Risk Assessments, the identified threats and typologies and the current risk environment. Existing guidance has been clarified and where appropriate expanded on the application of the risk-based approach (RBA), including consideration of risks arising through wider business relationships, B2B arrangements and group structures, as well as customer and beneficial ownership risks. 

The guidance has been refreshed across numerous areas such as Business, Customer and Technology Risk Assessments (BRA, CRA and TRAs), identity and verification, customer due diligence (CDD) and enhanced due diligence (EDD), payments and transaction risks, Terrorist Financing / Proliferation Financing (TF/PF) and financial sanctions, internal and external reporting procedures, staff training and appointments. 

GSC supervisory expectations have also been clarified where appropriate and links to relevant national and international guidance, typologies and resources have also been updated. In addition, the document has had a cosmetic overhaul, with diagrams refreshed. 

The GSC would like to emphasise that the underlying Code requirements remain unchanged.

What should you do?

At this time operators should prioritise reviewing the updated guidance over other recent GSC publications and consider any changes that may be required to their AML/CFT/CPF frameworks. Any necessary updates should be made as soon as practicable following the review.

The GSC is also progressing updates across its wider suite of AML/CFT guidance documents, including guidance for Software Suppliers and OGRA Licence Holders with Network Services Permissions, as well as the Guidance for Virtual Assets/Goods. Operators are encouraged to contribute to the development of these materials. The GSC welcomes suggestions on areas where further guidance or clarification would be helpful.

Operators which are interested in contributing more directly to the development of particular guidance documents are welcome to provide their suggestions or feedback to the GSC via gscamlinspections@gov.im.

For more information on the guidance, operators may get in touch with their preferred contact at the GSC for assistance or to organise a drop-in session at the GSC offices where staff will be available to assist you.