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.

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MERKUR Casino UK has committed a £100,000 donation to Momentum Children’s Charity that will be used to support families with seriously ill children. The donation marks a new partnership, that will span over a three-year period.

Momentum supports families across London, Surrey, and Sussex whose children are facing cancer or a life-challenging condition, offering personally tailored support to the entire family through their family support workers, both in hospital and at home. Momentum has grown significantly over the last 21 years, expanding their reach and impact across the hospitals and communities they work with. If the unthinkable happens, and a child dies, the charity has a specialist bereavement service called Momentum Echoes.

The funding from MERKUR will play a crucial role in supporting the charity’s future vision, helping Momentum deliver and expand a range of initiatives including opportunities for families to enjoy a day out on the charity’s riverboat or take a break in one of its respite cabins, offering space to rest, reconnect and create treasured memories.

MERKUR’s donations will also ensure that the charity can continue with Momentum Echoes, their bereavement support programme, which helps families navigate the unimaginable loss of a child.

MERKUR announced the partnership at the end of last year at their annual company conference. As demand for Momentum’s support grows, the impact made by MERKUR’s partnership comes at a time where making a positive difference to the lives of these families and children is vital.

Sarah Woods, CEO of Momentum Children’s Charity said: “We are delighted to be partnering with MERKUR Casino UK and are extremely grateful for their generous support. This partnership will allow Momentum to continue providing vital emotional and practical help to families who have a child with cancer or a life-challenging condition. Over the next three years, this support will enable us to reach more families and respond to the growing demand for our services. With the first donation already received, we can already see the difference this partnership is making.”

Mark Schertle, chief operating officer of MERKUR Casino UK, said: “At MERKUR, we strongly believe that giving back to the communities we serve is important, especially when it comes to supporting those who are facing heartbreaking challenges. Momentum Children’s Charity provides invaluable and exceptional support to the families and children affected by cancer and life-challenging conditions, helping them to cope more easily whatever the outcome. Their services provide essential counselling, creative therapies, experiences and respite breaks, all of which make a real difference in people’s lives. We are glad that our partnership, and donations to follow, will help Momentum continue their hard work and we are looking forward as to what lies ahead.”

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Wiebe Ruttenberg has joined the Board of Directors of the Netherlands Gambling Authority (KSA) on March 1. As a member of the Board of Directors, he will be responsible for Digital Transformation.

Wiebe Ruttenberg has experience as a board advisor at Bunq and SecAlliance and as a guest lecturer in Operational & Cyber Resilience at the European University Institute. He previously served as Programme Director for Cyber Resilience Strategy at the European Central Bank and held various positions at De Nederlandsche Bank (DNB) and the Ministry of Finance.

Michel Groothuizen, Chairman of the Board of Directors of the Netherlands Gambling Authority, said: “I’m pleased with Wiebe’s arrival as a member of the Executive Board, responsible for Digital Transformation. The rise of illegal gambling sites, cryptocurrencies, and AI applications are just a few examples that require the KSA to continue evolving into a data-driven and risk-driven organization, with an innovative toolkit that allows it to tackle illegal providers in new ways. A key challenge in this regard is establishing collaborative relationships with public and private parties, including those within the financial sector. I’m pleased that Wiebe, with his extensive knowledge of and experience with the financial sector, technological innovation, and European decision-making, brings the external perspective the KSA needs in this area.”

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