The Isle of Man Gambling Supervision Commission (GSC) has published new anti-money laundering and counter-terrorist financing guidance for online gambling licensees holding network services permissions, providing expanded compliance direction for one of the jurisdiction’s more complex licensing categories.
The document, effective from October 2025, is designed to help operators align their controls with the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 and 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 released earlier this year.
The GSC said the new guidance responds to industry requests for deeper insight into how the Code applies to network models, licensing arrangements that allow Isle of Man operators to host or supply technology to other online casinos. Such setups can present additional financial crime exposure due to their multi-party and cross-border nature.
The 20-page document outlines how license holders are expected to apply a risk-based approach, with specific emphasis on assessing network partners, understanding jurisdictional risks, and documenting enhanced due diligence processes. It reminds operators that by seeking Isle of Man licensing, they commit to “a high standard of governance, integrity, and regulatory oversight,” and stresses that failure to report or detect criminal conduct may lead to liability under the Proceeds of Crime Act 2008.
The GSC’s expectations include maintaining documented risk assessments, ongoing monitoring, and independent assurance measures to verify partners’ AML and compliance frameworks. Red flag indicators highlighted include reluctance to provide due diligence documentation, complex or opaque ownership structures, unexplained third-party payments, and associations with higher-risk jurisdictions.
The regulator also underscores that network activities – while not directly customer facing – may still pose elevated terrorist financing risks due to their interaction with third-party casino operators. As a result, the guidance advises licensees to tailor controls and staff training to the distinct nature of network operations. Inspections will continue to follow a risk-based model, with the GSC reviewing both the technical adequacy and real-world effectiveness of each operator’s AML framework. Repeated or serious failings may lead to enhanced supervision or escalation to the Commission’s enforcement division.
In publishing the guidance, the GSC reiterated that compliance not only safeguards businesses from regulatory action but also protects the island’s reputation as a leading, well-regulated online gambling hub. The Isle of Man remains compliant with 39 of the FATF’s 40 recommendations, placing it among the most technically compliant jurisdictions in the world for AML/CFT standards.
