Summary of the Gambling Supervision Commission (GSC) AML Forum meeting.
18th August 2023 saw the second Gambling Supervision Commission (GSC) AML Forum meeting of 2023. Claire Byrne and Lauren Mckinley attended on behalf of Impact Professional Services.
The update from the GSC was particularly useful with plenty of important information for industry, including recommendations and feedback following supervisory visits which we can all learn from.
Overview of current licence numbers and trends.
There are currently 91 companies licensed with the GSC, with more applications in progress.
The GSC have identified a number of trends during recent supervisory visits to licence holders:
- The requirements (Gambling Code 2019, paragraph 30) for the transfers of blocks of business are not being met. If issues are identified, consideration must be given to self-reporting to the GSC.
- Operators not following their own procedures / controls.
- There have also been cases of a notification of a change in or surrender of licence following a firm being notified of a GSC supervisory visit
The next onsite visit is likely to be late 2025, early 2026. The process will be broadly the same as the previous visit. If there is a poor result, it may mean a grey listing for the Isle of Man. The GSC will contact the Operators who are chosen to speak to MONEYVAL. MONEYVAL is likely to focus on the gambling sector.
The Isle of Man Government is highly committed to AML international standards. Work is required to review the National Risk Assessment (NRA).
- Prioritisation & resourcing – the GSC is focusing on AML, scaling back in other areas of supervision.
- Written word – the GSC is planning to update guidance, but there are no plans to update the Gambling Code 2019.
- The GSC will continue with their risk-based approach. There is a revised appetite for enforcement.
- Measuring & reporting – a joint GSC / FSA reporting system is under development.
Supervisory Visit Feedback
- A good Business Risk Assessment (BRA) shows a good understanding of the relevant Operators business.
- It is useful to show the BRA in a table format, showing the Code risk factor, along with the probability of the risk to the business and the associated mitigating measures.
- The GSC recommend that businesses incorporate the Isle of Man National Risk Assessment (NRA) sector findings and also the NRA from the country where the Operator’s target markets are.
- The BRA must be regularly reviewed and updated when there are significant changes. There must be a version control at the front.
- Do not confuse AML and commercial risks.
- A good Technology Risk Assessment (TRA) also has a version control and shows evidence of being signed off by senior management and reviewed at least annually. Separate the AML and the non- AML risks.
- Include a clear and concise explanation of the risks to the business, be specific not general. The TRA must be included within the documentation submitted to the GSC as part of the supervisory self-assessment stage.
- A good Customer Risk Assessment (CRA) includes all the risk factors noted in the Gambling Code 2019. If there are thresholds, ensure these are included. Illustrate whether the risk assessment has been completed using manual or automated checks. Any system checks should be checked / audited and included within any Compliance Monitoring.
- CRA’s should be regularly reviewed with additional commentary provided.
- Operator policies must align to the CRA process.
All operators need to have procedures and controls in place to identify sanctioned persons. Furthermore, there needs to be a procedure to freeze accounts, report suspicions / frozen accounts and there should be training & awareness for all staff.
What support is available?
At Impact Professional Services we support a number of GSC Regulated businesses in respect of their compliance responsibilities through licence application, compliance monitoring and mentoring.
We also offer interactive, CPD accredited AML training for GSC regulated businesses, ensuring your business is ready for renewed and increased focus on AML compliance ahead of the MONEYVAL visit. You can learn more and watch a demo today here.
To talk to us about our pragmatic and affordable compliance support, contact us today on email@example.com or 01624 820601.