13 July 2026: APG release a report on Cyber Scam Hubs and Human Trafficking
The Asia-Pacific Group on Money Laundering has released a report entitled “Cyber Scam Hubs and Human Trafficking.”
The Asia Pacific Group (APG) are an international government organisation founded in 1997 and is one of the largest FATF-style regional bodies (FRSB), including membership of 42 jurisdictions. The remit of the APG is aligned to that of Europe’s FRSB MONEYVAL and is to conduct mutual evaluations of compliance with FATF AML/CFT, to provide technical assistance to member jurisdictions on AML/CFT frameworks and to work with other international bodies such as the IMF, United Nations and INTERPOL.
The report estimates that scam centres generate tens of billions of US dollars annually and identifies increasingly sophisticated criminal networks, operating through complex corporate structures, payment systems, technology platforms and cross-border business relationships.
“Various estimates suggest cyber scam hubs are generating tens of billions of US dollars annually.”
Many of the risks in the report are consistent with those highlighted in the IOM Gambling Sector National Risk Assessment and recent international reporting concerning evolving methods used by organised crime groups, particularly in South-East Asia.
Typologies
The report identifies a number of typologies and risk indicators that may be relevant to online gambling businesses, software suppliers and network operators and any related service providers including –
- The use of complex and opaque corporate structures to obscure ownership, influence or control.
- Exploitation of special economic zones and high-risk jurisdictions.
- Criminal misuse of business-to-business (B2B) service providers, technology platforms and payment infrastructure.
- The use of fraudulent investment schemes, romance scams, phishing and other cyber-enabled frauds to generate criminal proceeds.
- Human trafficking and labour exploitation linked to cyber scam compounds operating under the guise of legitimate businesses.
- Use of mule accounts, account takeover and layered payment flows.
- Concealment of criminal activity through interconnected corporate ecosystems spanning gambling, payments, software development, marketing and digital services.
- Use of unlicensed or poorly regulated financial intermediaries.
- The movement of funds through multiple jurisdictions, creating barriers to effective oversight and investigation.
The APG report notes that modern organised crime groups increasingly operate through networks of legitimate-looking companies rather than relying solely on traditional concealment methods such as nominee directors or hidden beneficial ownership.
Key Challenges
The report notes several challenges faced by authorities internationally. International co-operation remains a significant issue, with 76% of law enforcement respondents noting that the cross-border nature of the threat was a key challenge, notably in relation to securing international cooperation and getting timely responses.
Tracing criminal proceeds, particularly where they move through multiple jurisdictions, complex corporate structures, payment intermediaries and rapidly evolving technology platforms, is noted as a key challenge in the report.
For gambling operators and service providers, these challenges reinforce the importance of understanding wider group structures, third-party relationships, supply chains, payment arrangements and jurisdictional exposures alongside customer activity.
Good Practices
The report identifies a number of good practices which align closely with the GSC's supervisory focus on risk-based approaches and emerging typologies.
These include-
- Enhanced scrutiny of complex ownership, control and group structures.
- Greater understanding of third-party service providers, software suppliers and business partners.
- Ongoing monitoring of jurisdictional exposure and cross-border business activity.
- Strong intelligence-sharing and cooperation between regulators, law enforcement and industry.
- Continuous AML/CFT training and professional development for compliance staff.
- Improved escalation processes where multiple lower-level risk indicators emerge over time.
- Enhanced use of open-source intelligence and adverse media screening.
- Greater awareness of organised crime typologies, cyber-enabled fraud and human trafficking indicators.
Keeping Steps Ahead
Many of the risks identified in the APG report have already been recognised within the Isle of Man's National Risk Assessment and Gambling Sector National Risk Assessment. The GSC has therefore continued to strengthen its understanding and supervision of emerging organised crime threats, particularly those involving complex corporate structures, cross-border business relationships, payment ecosystems and B2B gambling activity.
The GSC has incorporated emerging typologies associated with South-East Asian organised crime networks, cyber-enabled fraud and interconnected corporate ecosystems into its risk assessment and supervisory frameworks. Recent enhancements to supervisory tools, data analytics and intelligence processes are designed to identify risks that may not be apparent through traditional customer-focused monitoring alone. These include greater scrutiny of group structures, connected entities, software suppliers, third-party relationships and jurisdictional exposure.
The findings of the report also support the work currently being undertaken through the Isle of Man Financial Crime Partnership, where authorities and industry representatives are considering emerging risks affecting the e-gaming sector, including the misuse of payment systems, B2B service providers and wider corporate networks. The Partnership provides a mechanism for information sharing, horizon scanning and collaborative risk mitigation across government and industry.
The GSC has issued and updated sector-specific AML/CFT guidance for software suppliers and network operators, expanded data collection relating to B2B activity and strengthened expectations around third-party due diligence, ownership transparency and governance controls. These measures reflect the growing international understanding that material risks may arise outside the licensed gambling activity itself and may sit within wider group structures or associated businesses.
In addition, the National Risk Appetite Statement for eGaming published in May 2025 and the actions arising from the Gambling Sector National Risk Assessment have reinforced the importance of enhanced scrutiny of complex ownership structures, higher-risk jurisdictions, payment arrangements, corporate networks and emerging organised crime typologies. The GSC continues to work with domestic and international partners to ensure that these risks are reflected within licensing, supervision and AML/CFT controls.
The GSC encourages all licence holders to review the report and consider whether their existing AML/CFT controls adequately address emerging risks associated with organised crime, cyber-enabled fraud, human trafficking, complex corporate structures and wider business ecosystems.