Isle of Man GSC Issues New AML Guidance for iGaming Network Services Operators

Isle of Man Strengthens AML Framework for iGaming Sector

The Isle of Man Gambling Supervision Commission (GSC) has introduced new guidance for online gambling license holders operating with Network Services Permissions. Released around October 29-30, 2025, and becoming effective in October 2025, this comprehensive 20-page document is designed to bolster the island's efforts in combating money laundering (AML), the financing of terrorism (CFT), and proliferation financing (CPF) within its prominent iGaming sector.

The guidance expands upon the existing compliance framework, providing clearer direction for operators managing complex networked infrastructures that connect multiple gambling sites and platforms. It specifically addresses industry requests for deeper insight into how the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 applies to these intricate network models.

Key Pillars of the New Guidance

The GSC's updated directives underscore a commitment to maintaining the Isle of Man's reputation as a well-regulated and cooperative jurisdiction. The guidance aligns with recommendations from the Financial Action Task Force (FATF) and the Isle of Man's latest National Risk Assessments, reinforcing the island's compliance with 39 of FATF's 40 recommendations.

Central to the new guidance are several key expectations for license holders:

• Risk-Based Approach: Operators are required to tailor their AML and CFT controls proportionally to the scale and nature of their business operations.
• Enhanced Due Diligence: A strong focus is placed on customer due diligence (CDD) and enhanced due diligence (EDD), particularly for complex partnerships and network partners.
• Ongoing Monitoring: Licensees must implement continuous monitoring of transactional and behavioral patterns to detect suspicious activities.
• Robust Record-Keeping: Strict standards for record-keeping are mandated to support audit readiness.
• Third-Party Oversight: The guidance emphasizes critical oversight and clear communication channels when operators extend services to other gambling companies, especially those under different regulatory frameworks.

Addressing Network Services Permissions

Network Services Permissions are a specific licensing category that allows one operator to host games, provide systems, or deliver infrastructure for other licensed entities. This arrangement, by its multi-party and cross-border nature, inherently increases exposure to financial crime risks. The GSC's guidance acknowledges this reality, outlining expectations for proportionate risk management across both technical and operational layers.

Operators are expected to maintain documented risk assessments, conduct independent assurance measures, and provide targeted staff training to build awareness of risks linked to network operations. The guidance supports license holders in understanding their duties under the Proceeds of Crime Act 2008 and the Anti-Terrorism and Crime Act 2003.

Implications for Compliance

The GSC has made it clear that robust AML and CFT compliance is central to both the operational integrity and international credibility of the island's gambling industry. The Commission warns that repeated or serious failings in compliance may lead to enhanced supervision or escalation to its enforcement division, potentially resulting in liability under the Proceeds of Crime Act 2008.