Our Take on the Isle of Man NRAS (National Risk Appetite Statement) 15222

Authored by Scott Young, Operations Director 1d6b3h

Last week saw the publication of the anticipated National Statement on eGaming and Financial Crime (the NRAS). This significant publication serves to articulate the Isle of Man’s national risk appetite within the eGaming sector and, crucially, any other business sectors that may have activity linked to eGaming.

It reinforces the Island's comprehensive framework against money laundering (ML), terrorist financing (TF), and proliferation financing (PF). A broader National Statement, encoming the wider business landscape, is slated for release later in 2025.

Key Aspects of the National Statement

The NRAS clearly defines the acceptable types and levels of risk within both the eGaming and broader services sectors, serving as a clear line in the sand reference for all Isle of Man entities and, indeed, regulatory bodies. Its objectives include:

• Clarifying regulatory expectations regarding risk acceptance and mitigation.
• Strengthening governance across businesses operating within or servicing the eGaming and digital sectors.
• ing compliance decision-making, particularly in contexts involving higher risk or cross-border activities.
• Enhancing reputational resilience at both the business and jurisdictional levels.

This NRAS aligns with international best practices and underscores the Isle of Man’s commitment to being a jurisdiction committed to stamping out transnational organised crime while permitting responsible businesses to flourish.

The NRAS is ed by a comprehensive Typologies document issued by the Isle of Man Financial Intelligence Unit (FIU), which delineates methods and risks associated with specific high-risk activities and jurisdictions. All of the Isle of Man's business community, regardless of licensing or registration status, must consider both of these documents.

So what are the key takeaways?

The Isle of Man maintains a limited appetite for eGaming businesses exhibiting ownership and/or control originating from East or Southeast Asia, particularly when such affiliations are coupled with an accumulation of higher risk factors. In such instances:

• Regulators will refrain from authorising new business and will undertake reviews of existing licenses, citing their position outside the national risk appetite.
• For new business, all Isle of Man entities must consider identified risk factors and should not enter into new relationships where there is an accumulation of higher-level risks present that cannot be mitigated.
• In respect of existing business, the NRAS and ing FIU Typologies report should be considered a clear trigger event and promptly incorporated into business risk assessments as well as policies and procedures, including customer/client risk assessments with appropriate action and/or mitigating measures applied. It is also crucial to note that structures involving multiple distinct firms providing management services, such as directors, separate Money Laundering Reporting Officers (MLROs) present notably elevated risks regarding ML/TF/PF mitigation.

In a Nutshell

The National Risk Appetite Statement unequivocally underscores the Isle of Man’s commitment to maintaining its reputation as a leading international finance centre. This commitment is underpinned by a robust, adaptive, and intelligence-driven approach to combating financial crime. The statement signifies a clear strategic shift towards a more restrictive and targeted risk appetite, particularly within the eGaming sector, driven by a proactive response to identified threats and instances of infiltration by illicit actors. This demonstrates the Island's resolve to actively manage and mitigate risks rather than merely responding to them.

Key Things to Know

Clearer Rules: The document spells out exactly what's expected from businesses regarding risk management, making it easier to understand and follow the rules.

Stronger Protection: It's a commitment to beefing up defences against financial crime, enhancing the Island's reputation globally.

High-Risk Focus: There's a particular emphasis on increased scrutiny for businesses with links to East or Southeast Asia, or those showing multiple high-risk factors.

What Businesses Need to Do (Actions Required)

Read and Understand: If your business is in eGaming or provides services to it, you must review this new statement to understand the updated risk expectations.

Check Your Practices: Immediately update your AML/CFT Business Risk Assessment as well as internal policies and procedures, especially those related to assessing risks from customers and your own business operations.

Be Vigilant: If you're dealing with higher-risk situations (as defined in the NRAS and related FIU Typologies report), you must implement additional checks and controls. If risks cannot be managed, avoid new relationships or consider ending existing ones.

Report Concerns: It is mandatory to report any suspicions of money laundering, terrorist financing, or sanctions breaches to the Financial Intelligence Unit (FIU).

About the Author

As Director of Operations, Scott is charged with ensuring our business maintains the best-in-class services for which the company has become internationally recognised. With nearly two decades in the eGaming industry, he has a wealth of experience across multiple landscapes and business types. Having held previous MLRO and Board positions with a number of licensed entities, he is well versed in both the commercial and compliance complexities of the regulated sector and has a genuine ion for finding the right balance.

About Amber Gaming

At Amber Gaming, we understand what it’s like to carry the weight of operating in such a well-regulated, fast-moving industry. Amber Gaming is a specialist gaming consultancy business, providing multi-jurisdictional licensing, training, regulatory compliance advice and professional to both established and early-stage operators and software providers within the remote gambling industry. We're already working closely with clients to interpret the National Risk Appetite Statement and implement the necessary changes across their compliance frameworks. If you're unsure how this impacts your structure, customers, or future onboarding, we're to help. Feel free to get in touch with us via the Us form.