24 February 2026: Money Laundering Risk Assessment for Gambling Published
The Isle of Man Government has today published its National Risk Assessment (NRA) covering Money Laundering Risk in the Gambling sector.
The assessment identifies key threats of Money Laundering (ML) to the island’s Gambling sector (both Terrestrial and Online) and the materiality and impact of those threats. Both terrestrial and online gambling have been given a risk rating, with an overall rating for gambling as a whole. These risk ratings and key findings of the NRA feed into the wider NRA work, ensuring the Island has a comprehensive view of the entire threat landscape.
Why is this important?
Sectoral NRAs answer narrower versions of the NRA’s core question:
“Where is this sector exposed to ML/TF, and why?” The NRA aggregates, compares, and weighs the findings across all sectors to determine which risks drive national exposure. This ensures the NRA is not hypothetical: it reflects actual sector-level dynamics so that the Island can understand the ‘bigger picture’ with each sectoral assessment piecing together a border threat picture.
It is important that the island has a comprehensive understanding of risk at all levels, which does not reflect poor standards but instead outlines structural features of a sector. A robust NRA demonstrates that the jurisdiction understands its ML risks and applies targeted controls that are appropriate.
Risk Ratings
- The gambling sector overall is assessed as medium-high risk for money laundering.
- The online gambling sector has a medium-high risk, reflecting a large number of international customers and transaction volumes.
- The terrestrial gambling has a medium-low risk, reflecting its smaller size, domestic profile and lower transaction volumes.
Key Takeaways
The Sectoral NRA highlights core threats in both the online and terrestrial sectors, including:
- Criminal ownership and control of gambling businesses or B2B services, via front companies and complex corporate structures.
- Exploitation by organised crime groups, including those from East and Southeast Asia, for money laundering, cyber-enabled crime, and other illicit activities globally.
- Criminals use false or stolen IDs, synthetic identities, and mule identities to access gambling services and obscure their true identity to bypass due diligence controls.
- For terrestrial gambling, cash-intensive operations and casino-specific instruments remain primary channels for laundering domestic predicate offences.
It also highlights potential emerging threats such as:
- Use of advanced technologies (AI, deepfakes, virtual assets) to obscure identities, automate fraud, and facilitate cross-border transfers.
- Use of “turnkey solutions” (pre-packaged business setups) allowing rapid establishment of operations and access to banking services with minimal experience.
Importantly, the NRA makes it clear that these risks arise in specific circumstances with the sector operating legitimate international structures, strong governance and applying high standards of AML/CFT compliance. Those features that make activity higher risk for misuse should be considered within that context.
These emerging threats are not isolated to the IOM, but we have our part to play in combating the global threat of financial crime. The global landscape for gambling has evolved rapidly, shaped by technological innovation, changing market dynamics and the emergence of new and complex financial crime threats, and it is important to understand these threats in order to secure the sector.
The gambling sector continues to play an important role in the national economy, generating significant revenue and employment and acting as a key innovator.
It is essential that controls for online gambling, network services and software supply continue to be enhanced and for vigilance against both known and emerging threats, including those posed by advanced technologies and criminal infiltration, continues.
Operators must review their risk framework, including any relevant customer risk assessments and business risk assessments, in line with internal policies and procedures for a trigger event.
Operators must update their business risk assessment (BRA) to reflect findings from the latest NRA. Operators should also consider whether customer and technology risk assessments (CRAs, TRAs) also require revision. They are expected to demonstrate how identified risks have been considered and mitigated, ensuring systems and controls are effective and proportionate.
Collaboration / Cooperation
The Gambling Supervision Commission (GSC) would like to thank everyone who provided input into the NRA through data sharing or through feedback on the document.
“Collaboration between industry, government agencies and regulators is critical to maintaining the Island’s reputation as a well-regulated international finance sector and an outstanding place to do business.” - Jane Poole-Wilson MHK
In improving cooperation, enhancing data sharing capabilities, we can ensure the island remains a safe and competitive jurisdiction for legitimate business. A robust, well-regulated jurisdiction that comprehensively understands its risks and proportionately mitigates them provides clarity and stability.
Work is already underway to strengthen our controls, improve oversight, and enhance cooperation across Government, regulators, and industry. These findings will help ensure that the Isle of Man maintains a resilient, responsible, and internationally trusted gambling sector, aligned with our wider financial crime strategy.
The assessment underscores the island's commitment to safeguarding the future of the sector on the Isle of Man. Against an evolving threat backdrop, the GSC recognises the legitimate concerns of licensed operators and stakeholders, many of whom have seen growing uncertainty in markets and regulatory regimes. A strong NRA provides clarity for the future of the sector. The GSC works with operators navigating this increasingly complex environment, especially those working hard to maintain compliance and uphold high standards, offering one-to-one drop-in sessions, regular forums and a dedicated Outreach team.
The full document and key findings are available on the Isle of Man Countering Financial Crime website. All operators must understand and apply the findings of the NRA to their business risk frameworks.
