Licensees who are regulated by the Isle of Man Gambling Supervision Commission (the “GSC”) under the Online Gambling Regulations Act 2001 (“OGRA”) are expected to uphold the core principles of ensuring the gambling industry is kept crime free, protects the young and those considered at risk, and to ensure player protection through fair services and that players receive their true winnings.
In this regard, the Isle of Man Gambling (Anti Money Laundering and Financing of Terrorism) Code 2019 (“the Code”) sets out the responsibilities and expectations of licensed entities to prevent their operations being subject to money laundering and terrorist financing risks. Within this Code, Paragraph 7 covers the requirement for the business to conduct technology risk assessments.
A Technology Risk Assessment (“TRA”) is an assessment that estimates the risk of money laundering (ML), or terrorist financing (TF) posed by technology used by a business. It allows the business to acknowledge the risks posed and demonstrate the mitigations and controls in place to reduce any identified risks.
In accordance with the Code, a TRA should ideally be carried out prior to the introduction, or launch, of a new technology within the business. However, given the challenges, this may not always be possible and therefore the Code does allow for the assessment to be undertaken as soon as reasonably practicable after commencing business.
The following scenarios would result in a Technology Risk Assessment being required.
Consideration should also be given to non-AML/CFT matters such as the risk of hacking or data protection issues
The TRA’s should be recorded in a TRA Register and reviewed on a regular basis to ensure this is kept up to date.
The following list is our top tips for conducting a successful TRA:
The GSC have published guidance in the form of their AML/CFT Guidance for Operators 2020. This provides operators with an overview of the policy and guidance on key considerations and methods of implementation.
At Amber Gaming, we understand what it’s like to carry the weight of operating in such a heavily regulated industry. If you would like to receive further guidance, support, or training regarding TRA’s, feel free to get in touch with our expert team via our Contact Us page.