10 November 2026: PF Survey 2026 - Gambling Sector Steps Up Awareness

The GSC’s 2026 Proliferation Financing (PF) Operator Training and Awareness Survey shows a clear improvement in PF awareness across the gambling sector since the first survey was undertaken in 2024.

 

The 2026 PF Survey aimed to assess developments since the 2024 survey and provide an evidence base for the GSC’s ongoing risk-based supervision and outreach. It also supports delivery of the Isle of Man National Action Plan 2026–2031, which includes a specific action for the GSC to reissue the PF industry questionnaire, assess progress across sectors and identify whether further PF-specific supervisory measures, data requests, outreach or guidance may be required. 

 

Whilst the survey findings reflect operators’ self-assessments, they will inform the GSC’s future outreach, engagement and risk-based supervision, including testing whether reported understanding is reflected in effective controls.

 

Key findings

• PF awareness and integration into operators’ frameworks have improved since 2024. 94% of repeat respondents and 85% of first-time respondents reported taking action to strengthen understanding;
• Among repeat respondents, 80% reported improved awareness; the remaining 20% said awareness was already high;
• GSC and partner-agency outreach has prompted framework changes. Training is broadly established, generally annual and tailored to operators’ risks. Combined ML, TF and PF training remains appropriate where each risk is clearly addressed;
• Board oversight should ensure adequate resources and address knowledge or control gaps. The GSC will use the findings to inform outreach and test effectiveness in practice.

 

The PF Survey In Context

The survey’s publication is also an opportunity to remind operators that, as covered in the PF NRA, PF activity may pass through third countries or intermediary jurisdictions to conceal links to sanctioned states, entities or end users. Operators should watch for unusual geographic connections, payment routes or corporate structures with no clear commercial rationale. The PF typologies fact sheet has also been updated to raise awareness.

 

Drawing on The Royal United Services Institute (RUSI) Guide to Conducting a National PF Risk Assessment (2019), the PF NRA[1] considers China, Pakistan and Russia as possible states of PF concern in its analysis. The ML NRA highlights financial sanctions evasion and circumvention through third countries, including Türkiye, Azerbaijan, Georgia and Kazakhstan, and wider illicit-finance routing risks involving the UAE and Hong Kong, China[2].

 

Operators should assess country links alongside other relevant risk indicators. Operators should also monitor geopolitical developments and remain alert to the use of other jurisdictions to circumvent sanctions or divert funds or goods to sanctioned destinations or end users.

 

What should operators focus on next?

While the results demonstrate positive progress, PF remains an evolving risk, and operators should consider the following:

• Low likelihood does not mean no risk. Operators should assess indirect vulnerabilities and potential consequences, reflecting the NRA’s medium-low likelihood and medium consequence ratings;
• Keep pace with international risks. Limited domestic cases make international typologies and emerging risks particularly relevant, including developments in financial centres and online gambling jurisdictions;
• Reflect relevant findings from the 2025/2026 National Risk Assessments, including the standalone PF NRA, within risk assessments, controls and training;

• Ensure PF training covers relevant typologies, red flags, sanctions obligations and business-specific risks;
• Keep frameworks current as geopolitical developments and international PF typologies evolve; and
• Look out for more GSC guidance in this area, including more practical PF examples for online B2C, B2B and terrestrial operators.

 

Continued public-private collaboration between regulators and the private sector will help translate improved PF awareness into effective, risk-based controls, supported by targeted outreach, guidance and supervisory testing of risk understanding and controls in practice.

 

The full 2026 survey report can be found on the GSC publications page.