15 December 2025: Gambling Typologies, OCGs & Criminal Ownership

Earlier this year, the Isle of Man Financial Intelligence Unit released a report entitled "Online Gambling: Red Flags and Typologies for Money Laundering, Terrorist Financing, and Proliferation Financing". The increasing success and popularity of the online gambling industry has brought an increasing risk of businesses in this sector being used to facilitate financial crime. The FIU document is intended to assist professionals across a range of reporting sectors to identify signs of potential money laundering (ML), terrorist financing (TF), and proliferation financing (PF) associated with online gambling. 

The example below summarises a key typology identified in the document, which focuses on the use of gambling companies by Organised Crime Groups (OCGs) to launder proceeds of crime.

 

Typology Example

OCGs utilise chains of non-regulated digital-led business (e.g. software supply), which gives them the ability to move large volumes under the cover of a regulated activity. Cross-jurisdictional money flows are tied to a licensed hub to look legitimate, fragmented across multiple regulators, professional service providers, jurisdictions, etc. 

OCGs build legitimacy by ingratiating themselves into local government and communities: providing sponsorship, capital projects, economic boosts and employment. 

The money flows from under-regulated jurisdictions - using digital business models - to a regulated jurisdiction where a government-issued licence is held within the group. 

This ML model uses corporate-level flows rather than traditional customer-led risks, circumventing AML/CFT regulation.

This typology indicates that risk has shifted away from customer-based risk to a more sophisticated form of criminal ownership and control of clusters of interconnected digital-led companies. 

 

 

Red Flag Indicators

The graphic below highlights some key red flag indicators of this typology. For more information regarding key red flag indicators of ML/TF/PF in the gambling sector, the GSC Publications Page is also regularly updated with relevant flags and typologies fact sheets, as well as links to relevant reports. 

 

The GSC is constantly reviewing and assessing emerging typologies, both nationally and domestically. The sector and risk threat is constantly evolving, and so our measures, including entry controls, require review and enhancement based on potential new and emerging typologies. The GSC is committed to being agile and responsive in our approach to understanding risk, and works closely with all relevant partner agencies, including the FIU and law enforcement, to ensure a comprehensive understanding of risk.

The GSC thanks Operators for their prompt and effective initial response to the published document earlier this year, and reiterates that Operators must also consider all relevant typologies as part of their ongoing risk management framework. The GSC will continue to share relevant typologies with stakeholders in line with its key primary objectives.

 

For more information on this and other relevant typologies, the full FIU report is available on the FIU website.