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IoM To Launch Gambling AML/CTF Code

by Jason Gorringe,, London

12 December 2012

The Isle of Man government has released for comment three new Anti-Money Laundering and Countering the Financing of Terrorism Codes, including a new regime dealing solely with Manx-licensed gambling services providers.

The Money Laundering and Terrorist Financing (Online Gambling) Code 2013 is to introduce a bespoke framework for gambling operators, requiring that they establish, maintain and operate:

  • Robust identification procedures: dealt with in Paragraphs 5 and 11, the Code in particular prohibits gambling operators from accepting business from any person that uses an anonymous account, or an account with a fictitious name; and requires licence holders to continually monitor existing accounts. In addition, the Code emphasizes that winnings may only be transferred to a bank account bearing the same ownership information as an account.
  • Record keeping procedures: the rules, contained in Paragraphs 12 and 15 of the Code, require licence holders to retain records for at least six years, and make these available on request to Manx authorities within seven days.
  • Internal reporting procedures: the Code requires each licensed operator to employ a dedicated Money Laundering Reporting Officer, and clarifies the requirements placed on these persons.
  • Staff screening and training procedures: provisions seek to ensure that staff operate with integrity, and that operators exercise due caution when hiring.
  • Risk assessment: the Code requires gambling operators to undertake regular and thorough risk assessments, based on the value of funds deposited with the licence holder; the jurisdiction of the participant; and the source of the funds deposited. Licence holders must also take into account supervisory or regulatory guidance provided by the Isle of Man Gambling Supervision Commission. If a participant is flagged as higher risk, the licence holder must undertake enhanced due diligence measures outlined in Paragraph 10 of the Code.

In addition, the Code stipulates the procedures and controls that must be in place, notably requiring licence holders to keep pace with technological developments to better identify illegitimate money flows, and implement best standards in respect of risk monitoring and assessment.

The consultation, which also covers the draft Money Laundering and Terrorist Financing Code, and the draft Proceeds of Crime (Business in the Regulated Sector) Order 2013, is to run until January 31, 2013.

A comprehensive report in our Intelligence Report series examining the new possibilities that offshore e-commerce open up for business, and analysing the offshore jurisdictions that have led the way in offering professional e-commerce regimes for international business, with a particular focus on e-gaming, is available in the Lowtax Library at and a description of the report can be seen at
TAGS: money-laundering | Isle of Man | compliance | training | law | international financial centres (IFC) | enforcement | offshore | gambling | legislation | standards | regulation

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