Key Points
- Version 1.4 of GSC guidance issued on 10 November 2026 brings scrutiny of B2B relationships, group structure, and beneficial ownership, with the Code staying untouched.
- The GSC’s penalty register lists penalties from 20 to 30 per cent of the original amounts. Celton Manx paid £3.94 million for its initial fine of £5.625 million.
- MONEYVAL completed its mission on 9 October, with its report to be discussed in May 2027 at plenary.
Isle of Man Regulator Takes a Turn From Players To Their Partners
The updated money laundering guidance of Isle of Man shifts the attention beyond casinos and bookmakers. “Operators should note that risk exposure may occur within the broader business ecosystem in which they operate,” says the new document. The Gambling Supervision Commission (GSC) issued the updated guidance on 10 November, without making any changes in the Code. Then what changed, if the requirements have stayed the same?
According to the document, “underlying code requirements have remained unchanged”, however, the updated guidance describes how the operator should interpret them. Closer attention to B2B relationship, group structure, and beneficial ownership risk is required. The operator “cannot solely rely upon shareholdings” because control and influence should also be considered. The updated wording applies to risk assessment in terms of business, customers and technology, identification, payments, sanctions, reporting and training. It also notes that network providers and software providers might restrict access to information about end users and shift AML/CFT responsibilities.
The GSC encourages operators to study the guidance first, and then review other recent GSC documents to address any shortcomings as soon as possible. If there are questions, booking an appointment at the GSC office is an option.
Two Compliance Reviews Are Now Overlapping for Operators
In March, the GSC required operators to conclude their review of the national risk assessments no later than 1 September 2026. The business risk assessments should be revised accordingly and approved by the GSC as soon as possible after this date. The November notice outlines another review, which is now needed to check compliance with the new guidance. Even those operators who have met the September deadline may have to revise their documentation once again.
February’s Risk Rating Reveals Why Partnerships Matter
In February, the GSC increased gambling’s money laundering risk rating from medium to medium-high. This rating increase occurred owing to the international clientele and significant transaction volume of online gambling. Land-based gambling continued to stay at the medium-low risk level. The assessment points to the criminal ownership of the operators or their suppliers as a key risk factor. Others include organized crime groups in East and Southeast Asia, synthetic identity frauds and technology abuse, and turnkey business solutions, which provide fast ways to set up gambling business and banking access. The risk statement issued in May 2025 already limited the regulator’s appetite for eGaming businesses operated from East or Southeast Asia.
Minister for Justice Jane Poole-Wilson said that there were “sophisticated organized crime groups operating across borders”. She saw this rating positively because, in addition to showing the threat level, “it highlights the strength of our controls to mitigate these”. As a result of the risk assessment, the GSC defined four objectives with prioritized supervision of the B2B relationships and supply chains. Also, the UK Gambling Commission expressed its intention to supervise B2B operations. This point is crucial since Britain is an important market for Isle of Man operators.
Software Supply Still Partially Outside GSC Licensing
In terms of assessment, software supply businesses make up a majority of profits declared within the industry. Yet GSC software licensing remains optional, meaning most of the software supply sector is not covered by its licensing regime. As per version 1.4, software suppliers licensed by the GSC have to meet requirements that include some AML/CFT regulations. There remains a query regarding the boundary between the GSC regulation and operator’s responsibility.
Operators of licensed services remain obligated to provide information about their suppliers, specifically independent proof of a software supplier’s probity. The legal guide of Appleby mentions that operators have to exercise best efforts to make sure that their unlicensed partners follow GSC fundamental principles. One of the license conditions requires GSC approval for anyone wishing to purchase more than 5% stake in the operator, with some exceptions. The threshold of beneficial ownership stated in version 1.4 is 25%, while control and influence carry equal importance.
Penalties Discounted up to 30 Per Cent
GSC register of civil penalties has five entries, with Cyberhorizon receiving the first one worth £140,000 in net penalty in September 2024. BMO Manx was the next in December 2024 with a penalty of £700,000. All penalties listed there have discounts applied, with a standard 30 per cent discount rate. The £100,000 penalty of SK IOM was reduced to £70,000 on 26 June 2025 due to a 30 per cent discount. Celton Manx had a discount of 30 per cent applied to its penalty reducing £5,625,000 to £3,937,500 on 3 July 2025.
Shelgeyr, related to Maverick Games, had a discount of 20 per cent on 6 February 2026 and now has a penalty of £200,000, originally set at £250,000. The statement of GSC regarding the Shelgiers penalty mentions the admitted failings and cooperation as considerations for calculation. Stating the Celton Manx penalty of £3.94m omits its discount of £1,687,500.
Personal Penalties for Executives Are Pending a Confirmed Date of Operation
Tynwald passed the Gambling Legislation (Amendment) Bill on 28 April 2026. This Bill allows for imposition of civil penalties on controllers, key persons and senior managers in case of a breach committed under their consent, connivance or negligence. On 8 July, the GSC stated that its civil penalties regulations were “substantially finalised” and invited final feedback on the guidance as drafted.
As per the regulator, the regime would only become operative once the guidance has been finalised and stakeholders notified. Regulation draft SD 2026/0149 provides for the commencement of the regime the day following the coming into force of section 91 of the 2026 Amendment Act. While the Royal Assent was anticipated on 21 July, no GSC news update published during September-November confirms it. Personal penalties will remain pending until the regulator announces the commencement date.
Visit by MONEYVAL Completed in Preparation for the 2027 Report
The MONEYVAL assessors completed the on-site assessment in Douglas during the period from 28 September to 9 October 2026. According to the plan, the report will be presented to and adopted by a MONEYVAL plenary during May 2027. Publication is scheduled for 2027, though an exact date has not yet been fixed.
In this sixth round of assessment, MONEYVAL will examine how effectively the island’s controls work in practice, not just whether they satisfy the written requirements. Standards in this round are much higher since the previous on-site assessment was conducted in 2016. In addition, the GSC is preparing new guidance for software suppliers, network services licence holders, as well as virtual assets and goods operators.
Expert Analysis: Can Guidance Take the Place of Law?
Our interpretation of version 1.4 is that it puts a lot of burden on operators. Despite no change in the Code, the guidance places a greater burden on operators by requiring them to conduct more comprehensive assessments of their business partners, beneficial owners, and organizational structures.
It will be useful to learn from the GSC whether omission of a business-to-business check in version 1.4 is in violation of the Code. Proponents can claim that the guidance enables the evolution of regulatory standards without the enactment of a new law. Opponents can claim that operators need clear delineation of what is recommendation and what is obligation.
The proposed penalties against executives will require this delineation to be particularly clear. While negligence is easier to prove than intent, we think that executives must know precisely what the guidance wants from them. We find discounts for self-reporting and cooperation with the regulator well-deserved, but readers must see the original penalties in every single headline along with the reduction.
According to GSC chief executive Mark Rutherford, the risk assessment is “a positive development for the Island”. In 2022/23 gambling comprised 14.2% of the national GDP, so the increased risk level was to serve as a warning before anything else. Until MONEYVAL publishes its report, operators face the following unresolved question: Who are the backbones of our business partners?
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