Nick Bowden, Head of Regulatory Affairs at SolutionsHub, provides expert commentary on the Isle of Man Gambling Supervision Commission’s (“GSC”) General Compliance & AML/CFT Supervision Visit Procedures document (“the Procedures document”).
The procedures document is a critical roadmap for Online Gambling Regulation Act 2001 (“OGRA”) licence holders.
The document outlines the procedures that the GSC typically employs during its AML/CFT and compliance visit (or audit), noting the expectations and requirements for remaining compliant with relevant regulations and guidance.
However, as issues arise in relation to AML/CFT or compliance, or where specific findings necessitate, the GSC may devise responses that are not encompassed within the guidance.
Supervision Visit Procedures: The Three-Part Visit Process
The visit process itself is composed of three parts.
Self-Assessment: The First Step
The process begins with a self-assessment. This is a critical component of the GSC’s overall audit process, where Operators are expected to provide detailed information about their processes and systems to demonstrate compliance with AML/CFT regulations. This information is then subject to a desk-based review by the GSC.
The Procedures document emphasises the importance of supplying the requested pre-visit information and should be returned well in advance of any scheduled visits in a timely manner. This allows the GSC to perform its desk-based checks and raise any necessary queries ahead of the visit. The late submission of information could result in delays or additional requirements to be considered during the visit.
Onsite Visit: Demonstrating Compliance in Action
The second part of the process is an onsite visit. During this visit, checks are carried out to ensure that the processes and systems are operating as they should in accordance with legislation. Demonstrations will be sought to verify the functionality of the operating systems in place and the control measures utilised to mitigate risk.
Post-Visit: Drafting the Report and Resolving Queries
The final part of the process is the post-visit period, which allows for a comprehensive review of the operator’s compliance status and the identification of any areas that may require further attention.
The post-visit period commences with the GSC issuing a draft report, following its onsite assessment. Once issued, any queries regarding the report are resolved between the Operator and the GSC. .
Any requirements marked as ‘not met’ or ‘partially met’ within the report will be accompanied by a remediation plan, to allow the Operator to make the necessary enhancements to its systems and process to align with the required standards.
Ensuring Compliance
Navigating the compliance landscape can be challenging, but with a clear understanding of the requirements outlined within the Procedures document, Operators can ensure they are well-prepared for any visits and can demonstrate their commitment to maintaining high standards of compliance to the GSC.
Gambling Operators must remember that compliance is an ongoing process and should stay informed and prepared to remain compliant.
If you have any questions regarding the GSC Supervision Visit Procedures or need assistance, please click the following link to book a consultation.
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