The Isle of Man has raised the threat level faced by the island’s gambling sector, while taking note of the continuing risks associated with Southeast Asian criminal networks and other challenges.
In its latest National Risk Assessment (NRA), the Isle of Man Gambling Supervision Commission (GSC) assessed that the island’s gambling sector as a whole is of ‘medium high’ risk of money laundering.
The online gambling sector has also been classified as medium high risk due to the large number of international customers and transaction volumes it attracts. The local industry has been classified as ‘medium low’ risk by comparison due to its smaller size and volumes.
The GSC’s decision to categorise the gambling sector as a whole as medium high risk is an upgrade from the last NRA, published back in 2020.
This NRA classified the sector as medium risk, with the regulator stating that increased global threats and recognised typologies over the past few years have prompted the upgraded profile.
“The Isle of Man’s reputation as an international finance centre depends on our willingness to confront and respond to emerging threats,” said Jane Poole-Wilson MHK, the Isle of Man’s Minister for Justice and Home Affairs.
“Whilst this National Risk Assessment highlights challenges – particularly from sophisticated organised crime groups operating across borders – it also shows the strength of our controls to mitigate these.
“I welcome this report and encourage all licence holders and associated sectors to use its findings to strengthen their controls and safeguard the Island’s standing as a well-regulated jurisdiction that welcomes high quality well-run business.”
New risk, same threats
Betting and gaming is a very significant industry for the Isle of Man and is the largest non-financial sector on the island according to the GSC. The regulator’s latest risk assessment puts the industry’s economic contribution at 14.2% of national income for 2022/23.
The island hosts a number of international gaming companies, many of which are registered and licensed locally but active across various other jurisdictions – whether using their Isle of Man licence or acquiring local ones as well.
Entain, one of the world’s largest betting and gaming PLCs, is arguably the biggest name to be headquartered on the island, with its activities spanning Europe and the Americas using locally held licences.
While the Isle of Man may have increased the risk profile of gambling, some of the risks and threats it has identified remain consistent with its 2020 NRA and with other risk statements made over the past couple of years.
The GSC has identified what it believes are core threats to the industry – criminal ownership and control of gambling businesses or software suppliers, exploitation of the industry by organised crime groups including ones in East and Southeast Asia, and the use of false or stolen IDs and/or synthetic identities.
Some readers will be familiar with the referencing of East and Southeast Asia in Isle of Man reports. Authorities as high up as the UN have become particularly aware of criminal activities in this region with relation to gambling, as well as to cryptocurrency, having voiced concerns in 2024 and 2025.
The regulator is also concerned about how technology can be used to enable exploitation and money laundering. Unsurprisingly, AI is on the agenda, particularly the tech’s use for creating deepfakes.
Virtual assets – we can assume the regulator is referring to cryptocurrency and other blockchain-related assets here – are also of concern, such as being used for cross-border transactions and to obscure identities.
Lastly, the GSC also believes that turnkey solutions being sold as pre-packaged business setups, allowing the quick establishment of operations and access to banking services, are also posing a threat to industry.
Where next?
The GSC has identified four key objectives based on its latest risk assessment. The first of these is to continue developing supply chain risk understanding, and enhance supervision of B2B arrangements.
This comes amid wider regulatory change in the nearby UK, of which the Isle of Man is a Crown Dependency of and which stands out as a major market for many companies headquartered, licensed and/or registered on the island.
The UK Gambling Commission (UKGC) has pledged to keep a closer eye on how B2B activity might support the black market, for example. Also, white label agreements on the Isle of Man have faced some scrutiny lately, particularly regarding the collapse of TGP Europe in spring last year.
Secondly, the GSC wants to improve data analytics and intelligence sharing, not just across betting but also in associated industries. Again, this is something the UKGC has had on its agenda for some time, encouraging more cooperation with the banking sector.
The GSC also wants to provide targeted outreach and guidance around suspicious activity reporting, and achieve better understanding of the extent of structures involved in unregulated gambling businesses. This could be quite an intensive endeavour, given the global scale of the black market.
So, what does the GSC expect from the industry? The regulator has kept it brief, encouraging operators to incorporate risk assessment findings into their business practice, remain vigilant about known and emerging threats, and assess any other risks within or impacting their own operations.
It is also encouraging the industry, regulators and related financial sectors to engage in further collaboration around compliance – soemthing seen at the international level lately as more and more regulators become fixated with clamping down on black market betting.
Mark Rutherford, Chief Executive of the GSC, said: ‘This assessment shows clearly that while the Isle of Man faces the same evolving global threats as other leading jurisdictions, our regulatory framework has continued to strengthen and adapt.
“We have increased our supervisory intensity, expanded our enforcement tools, and deepened cooperation with domestic and international partners. The findings give us a sharper lens on where risks lie — particularly around complex cross border structures, technology driven threats and B2B arrangements — and they equip both the GSC and industry to respond decisively.
“This is a positive development for the Island: it reinforces our reputation as a responsible, forward-looking jurisdiction committed to maintaining the integrity of its gambling sector.’