The Isle of Man government has published its updated National Risk Assessment (NRA) for the gambling sector.
The assessment identifies key threats of Money Laundering (ML) to the island’s Gambling sector (both Terrestrial and Online) and the materiality and impact of those threats. Both terrestrial and online gambling have been given a risk rating, with an overall rating for gambling as a whole. These risk ratings and key findings of the NRA feed into the wider NRA work, ensuring the Island has a comprehensive view of the entire threat landscape.
The NRA aggregates, compares and weighs the findings across all sectors to determine which risks drive national exposure. This ensures the NRA is not hypothetical: it reflects actual sector-level dynamics so that the Island can understand the “bigger picture” with each sectoral assessment piecing together a border threat picture.
It is important that the island has a comprehensive understanding of risk at all levels, which does not reflect poor standards but instead outlines structural features of a sector. A robust NRA demonstrates that the jurisdiction understands its ML risks and applies targeted controls that are appropriate.
Risk Ratings are as follows:
• The gambling sector overall is assessed as medium-high risk for money laundering.
• The online gambling sector has a medium-high risk, reflecting a large number of international customers and transaction volumes.
• The terrestrial gambling has a medium-low risk, reflecting its smaller size, domestic profile and lower transaction volumes.
Key Takeaways
The Sectoral NRA highlights core threats in both the online and terrestrial sectors, including:
• Criminal ownership and control of gambling businesses or B2B services, via front companies and complex corporate structures.
• Exploitation by organised crime groups, including those from East and Southeast Asia, for money laundering, cyber-enabled crime and other illicit activities globally.
• Criminals use false or stolen IDs, synthetic identities, and mule identities to access gambling services and obscure their true identity to bypass due diligence controls.
• For terrestrial gambling, cash-intensive operations and casino-specific instruments remain primary channels for laundering domestic predicate offences.
It also highlights potential emerging threats such as:
• Use of advanced technologies (AI, deepfakes, virtual assets) to obscure identities, automate fraud, and facilitate cross-border transfers.
• Use of “turnkey solutions” (pre-packaged business setups) allowing rapid establishment of operations and access to banking services with minimal experience.
Importantly, the NRA makes it clear that these risks arise in specific circumstances with the sector operating legitimate international structures, strong governance and applying high standards of AML/CFT compliance. Those features that make activity higher risk for misuse should be considered within that context.
