GSC tells operators to review customer risk after AML list changes

The Isle of Man Gambling Supervision Commission (GSC) told operators on 3 November 2026 that the Department of Home Affairs (DHA) had amended the Isle of Man’s anti-money laundering and counter-terrorist financing country lists following the October 2026 FATF Plenary. The changes apply from 30 October 2026.

The GSC’s notice means operators should review whether the changes affect customers, business relationships or activity within their existing risk assessment frameworks. It does not require every affected customer or relationship to be automatically reclassified, except where requirements relating to List A apply. If an assessment identifies a customer as high risk, the enhanced customer due diligence requirements in the AML/CFT Code apply.

The changes

The DHA removed Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco from List B(i). Côte d’Ivoire was also removed from List B(ii).

Bulgaria, Côte d’Ivoire and Monaco were added to both List C and List D. The GSC points operators to the DHA’s clean and tracked versions of the updated lists.

The notice describes List B as a risk indicator that may indicate a higher risk of money laundering or terrorist financing. Operators should consider it alongside other relevant factors as part of a holistic customer risk assessment, rather than treating a country-list change in isolation.

For compliance teams, the practical task is therefore to test the revised country data against existing customer and activity profiles, then document whether the overall risk assessment changes. The list movement alone is not presented as sufficient grounds for a blanket reclassification.

Ongoing monitoring

The GSC says the lists support horizon scanning and operators’ ongoing understanding of jurisdictional risk. They should not be treated as a tick-box exercise. The GSC also refers operators to its 28 August 2026 guidance, “Country Lists: A Quick Guide”, on their appropriate use.

The update follows recent AML/CFT supervisory action by the same regulator. The GSC imposed a discretionary civil penalty on SK IOM Limited in July 2025 over AML/CFT Code contraventions and published the conclusions of an AML-focused investigation into Celton Manx Limited. It also imposed a civil penalty on BMO Manx Limited in December 2024.

The GSC’s message is that operators should incorporate the revised lists into continuing risk monitoring, while retaining an individual, evidence-based assessment of each customer and relationship.