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

Isle of Man Strengthens AML Framework for iGaming Sector

The Isle of Man Gambling Supervision Commission (GSC) has published new anti-money laundering (AML) and counter-terrorist financing (CFT) guidance specifically for online gambling licensees holding Network Services Permissions. This 20-page document, effective from October 2025, is designed to provide expanded compliance direction for one of the jurisdiction's more complex licensing categories.

The guidance responds to industry requests for deeper insight into how the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 applies to network models. These arrangements, which allow Isle of Man operators to host or supply technology to other online casinos, can present additional financial crime exposure due to their multi-party and cross-border nature.

Key Directives and Risk Mitigation

The new guidance emphasizes a risk-based approach to AML/CFT, with a strong focus on several critical areas. License holders are now expected to apply rigorous controls, including:

• Assessing network partners and understanding jurisdictional risks.
• Implementing and documenting enhanced due diligence processes.
• Maintaining detailed risk assessments that demonstrate how AML risks are identified and managed.
• Conducting ongoing monitoring of network partners and financial transactions.
• Establishing independent assurance measures to verify partners' AML and compliance frameworks.
• Providing targeted staff training tailored to the distinct nature of network operations.

The GSC has also highlighted specific red flag indicators, such as reluctance to provide due diligence documentation, opaque ownership structures, unexplained third-party payments, and associations with higher-risk jurisdictions.

Alignment with International Standards and Reputation

The updated guidance is a strategic move to align operators' controls with the recommendations of the Financial Action Task Force (FATF). It also draws from the Isle of Man's latest National Risk Assessment (NRA), the National Risk Appetite Statement (NRAS), and the Terrorist Financing National Risk Assessment, which was released earlier this year.

By issuing this guidance, the GSC aims to safeguard the island's reputation as a leading, well-regulated online gambling hub. The Isle of Man currently complies with 39 of the FATF's 40 recommendations, positioning it among the most technically compliant jurisdictions globally for AML/CFT standards. Operators are reminded that failure to report or detect criminal conduct may lead to liability under the Proceeds of Crime Act 2008.