Online gaming and gambling platforms are the centre point of an increasingly complex and sophisticated criminal landscape in East and Southeast Asia.
This criminal landscape has extended outside of East and Southeast Asia, impacting countries worldwide and there has become a need for increasing vigilance when conducting business linked to this region.
Given the Isle of Man’s well-established financial, non-financial and online gambling sectors which are globally attractive for customers, coupled with the geographical and constitutional links to the UK, the Island is attractive for exploitation by these transnational organised crime groups. This is a risk for international finance centres globally as a result of the international reach of their nature of business.
For over 20 years, the eGaming sector has been a significant contributor to the Island’s economy and continues to play an essential role and remains a vital component of the overall economy. As with many sectors that have an international focus, there is a constantly changing threat landscape which may increase the risk of exploitation.
Actions taken by Isle of Man authorities, which have been the subject of media attention, have clearly indicated that the Isle of Man has been subject to attacks by criminals to bypass the Island’s controls against financial crime and immigration. Law enforcement actions cannot be subject to further comment.
Jane Poole-Wilson MHK, Deputy Chief Minister and AML/CFT Lead for the Isle of Man Government said: “The Isle of Man Government and the Island’s authorities take the illicit actions by transnational organised criminals to exploit the Island’s business environment and immigration security extremely seriously.
“Significant and wide-reaching actions are being taken by agencies, with investment in law enforcement and investigation capability. This includes strengthening the Island’s immigration systems and processes. These actions aim to ensure that any vulnerabilities are identified, and that urgent action is taken to mitigate vulnerabilities, thereby strengthening the Island’s countering financial crime regime for the future.
“We will not tolerate the use of the Island for criminal activity and will not hesitate to act to disrupt and prosecute those responsible.”
The Isle of Man Government says it is committed to international anti-money laundering and countering terrorist and proliferation financing (AML/CFT/CPF) efforts as evidenced by the Island’s Financial Crime Strategy 2024-2026 which outlines the all-Island approach to tackling financial crime.
Given the threat picture, it is imperative that the Isle of Man authorities and industry across all sectors remain vigilant and mitigate vulnerabilities that can be exploited by organised crime groups.
The Isle of Man Gambling Supervision Commission (GSC), which supervises the e-gaming sector is reviewing and strengthening its framework and practices in market licencing, supervision and enforcement. This complements further investment by the GSC of a dedicated and fully resourced unit with experienced staff in AML/CTF/CPF.
The GSC have an enhanced programme of monitoring underway and continue to share information with agencies where they identify concerns. Alongside this, new licence applications will be subject to additional scrutiny whilst the framework and practices are under review and more information concerning the national risk appetite for new gaming licences with links to South and Southeast Asia will be published soon. Equally, to assist industry in the Island’s shared endeavour to remain vigilant against these threats, the authorities will publish further information concerning the types of risks and typologies being used in the near future.
The Isle of Man authorities are continuing to enhance inter-agency working across the regulators and law enforcement to further strengthen the financial crime prevention regime.
Further amendments to legislation and the national AML/CFT/CPF regime as well as the immigration regime are in development to combat and prevent organised crime of this nature.
More broadly, work is underway to produce an updated National Risk Assessment (NRA). This builds on previous NRAs completed in 2015 and 2020 and is a key tool in identifying, assessing, and understanding the money laundering and terrorist financing risks facing the Isle of Man. In order to mitigate the risks identified as part of the NRA, a National Action Plan will be developed, published and actions advanced which aim to continually strengthen the Island’s approach to financial crime.
Carrying out a NRA is one of the forty recommendations made by the Financial Action Task Force, the international standard setter on financial crime.
The Isle of Man’s compliance with these standards is set to be evaluated by MONEYVAL in October 2026 and significant preparations are underway for the evaluation.
The Isle of Man Government says they will continue to invest and prioritise work to ensure it prevents against harm to the Island and business community, complies with international standards and evidences its long-term effectiveness in AML/CTF/CPF, maintaining the Island’s position as a reputable international finance centre.
