The Isle of Man has published an updated national risk appetite statement focused on the eGaming sector, reinforcing a cautious regulatory approach – particularly toward operators with ownership or control links to East and Southeast Asia.
The revised statement, released May 29th, 2025, builds upon previous guidance and forms part of the jurisdiction’s strategic preparations for an upcoming MONEYVAL (Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism) evaluation.
The updated document reflects a broadening of the IoM’s risk sensitivity, no longer limiting concern to just new eGaming businesses. Instead, it outlines a limited national appetite for any business relationships involving entities with links to East or Southeast Asia, and states there is “extremely limited” appetite where multiple high-risk factors are present.
This change comes amid heightened global scrutiny of the financial crime risks associated with online gambling and digital services. The Isle of Man’s move is also backed by a suite of intelligence, including a growing body of reports from international organizations such as the United Nations Office on Drugs and Crime (UNODC) and the Royal United Services Institute (RUSI), which are explicitly cited in the national statement.
The updated position has practical consequences. License applications may be rejected outright, and existing relationships could be reviewed or even terminated where they fall outside the revised risk appetite. The government has designated the new guidance as a “trigger event,” meaning that all licensees and associated service providers must immediately reassess their customer and business risk profiles. Where risks cannot be mitigated, businesses are expected to unwind affected relationships.
The policy shift follows a string of investigations that have raised concerns about the Isle of Man’s regulatory framework. Among the most high-profile was the collapse of King Gaming, an incident that prompted international media coverage and placed the spotlight on the Island’s due diligence processes. Fallout from that case, as well as other law enforcement actions, has highlighted vulnerabilities that the updated guidance now aims to address.
Risk factors receiving increased regulatory scrutiny include overly complex or opaque corporate structures, inadequate transparency around beneficial ownership, and links to jurisdictions identified as high-risk by the Financial Action Task Force (FATF) or typologies set out by the Financial Intelligence Unit (FIU). The updated statement also flags operators with limited experience in eGaming or those relying on fragmented service arrangements – such as separate nominee directors, MLROs, and payment providers – as particularly high risk.
Importantly, the Gambling Supervision Commission (GSC) has affirmed that enhanced scrutiny will now be applied not only to primary license holders but also to software suppliers, network service providers, and other entities operating within the broader eGaming value chain. All affected parties are expected to align with the guidance and ensure they meet elevated standards of risk governance.
This national risk appetite statement is the first public iteration focused on a specific sector and forms part of the Island’s broader Financial Crime Strategy 2024–2026. It precedes the Isle of Man’s third National Risk Assessment, expected to be published in stages throughout 2025.
The release comes just months ahead of the Isle of Man’s long-awaited MONEYVAL evaluation. The outcome of that review could have significant implications for the Island’s standing with international standard-setters. Officials are understood to be taking a proactive stance to avoid any negative rating or potential grey listing, which could impact both its finance and eGaming sectors.
Government sources describe the updated guidance as a demonstration of the Island’s commitment to international best practices and a measured response to the evolving nature of transnational financial crime. “This is part of a robust national response,” the statement reads, referencing the complex and often multi-jurisdictional nature of criminal operations exploiting the online gambling sector.
For industry stakeholders, the updated statement has immediate and wide-reaching implications. All Manx-registered entities are expected to revisit their internal risk assessments, compliance frameworks, and customer onboarding procedures. Relationships that cannot be justified under the new guidance should be reconsidered or terminated.
While the Isle of Man has traditionally positioned itself as a top-tier regulatory jurisdiction with a business-friendly environment, this shift signals a recalibration of priorities. Regulatory authorities are now emphasizing defensibility, international alignment, and the protection of the Island’s global reputation over purely commercial incentives.
The firm stance on businesses with links to East and Southeast Asia may also prompt legal and policy debate. Critics may argue that broad restrictions – if applied too generally or without strong case-by-case analysis – could risk running afoul of principles enshrined in international law, such as non-discrimination, proportionality, and fair treatment. Legal observers will be watching closely to see how the GSC and other authorities implement the new framework in practice.
The GSC has reiterated that licensing decisions will continue to be made on a case-by-case basis, and the risk appetite statement is intended to provide transparency and consistency across those decisions.
A broader National Risk Appetite Statement, covering additional sectors beyond eGaming, is expected to be published later in 2025. Until then, the Isle of Man’s regulatory posture sends a clear message: risk-based supervision is being tightened, and operators will need to meet higher standards – or face consequences. With jurisdictions like Malta and Curaçao monitoring these developments closely, the international competition for eGaming business may soon shift, offering both risks and opportunities for operators navigating an increasingly complex regulatory landscape.
