Alderney Aces AML Review As Standards Rise Across Offshore Hubs

The Council of Europe’s anti-money laundering and counter-terrorism financing (AML/CTF) monitor, MONEYVAL, has delivered a generally glowing assessment of online gambling regulation in Alderney. The development forms part of a trend of AML standards rising across Europe’s traditional offshore hubs, just as a cohort of dubious operators fleeing the likes of Curaçao and the Philippines are searching for new homes.

After years of controversy involving Europe’s smaller online gambling regulators, this month’s 363-page report places the Bailiwick of Guernsey and its Alderney gambling regulator in the top tier for financial compliance, matching MONEYVAL’s recent praise for financial compliance on Jersey, another Channel Islands online gambling licensor.

The two jurisdictions’ solid assessments raise the bar for online gambling regulation on scandal-tainted Isle of Man, another crown dependency whose onsite mutual evaluation was confirmed for October 2026 by MONEYVAL two weeks ago.

MONEYVAL’s latest report found no substantial fault with gambling regulation nor with wider financial regulation in the Bailiwick of Guernsey, a UK dependency of which Alderney is part.

Its executive summary praised Guernsey’s Financial Services Commission (GFSC) and the Alderney Gambling Control Commission (AGCC) for their “very good understanding of [AML/CTF] threats and vulnerabilities to which the supervised sectors are exposed”.

The GFSC and AGCC responded to the report by saying the two organisations now “meet a standard only seen in four other jurisdictions worldwide”, and that the report found their outreach work with the private sector “abundant and remarkable”, with “no fundamental improvements” required.

“MONEYVAL confirmed that the Bailiwick has a very full and very contemporary set of regulations relating to AML, CFT and proliferation financing and these are very well communicated by its agencies and well understood by the public sector,” they said in a statement to Vixio GamblingCompliance.

The regulators also noted praise in the report for legal and other cooperation with counterparts in other countries, “demonstrating [Guernsey’s] commitment to being a responsible international partner”.

The report confirmed Guernsey’s “highest achievable level of compliance in two areas related to sanctions enforcement. Only the United Kingdom and the United States have scored as highly”, according to the statement.

“The MONEYVAL process can be challenging for smaller jurisdictions where resourcing with experienced and knowledgeable staff can be difficult,” AGCC chairman Lord Richard Faulkner said.

“But we are pleased that this evaluation found the AGCC is well prepared and that our relationship manager structure gives our eCasinos a ‘consistent, direct and immediate point of contact’.”

Faulkner said the result “rates very highly in any international comparison that can be drawn, particularly as this was the final evaluation in the [Europe-wide] fifth round, and expectations have been raised during that process”.

However, MONEYVAL called on Guernsey to improve on a very low number of prosecutions for money laundering and improve the quality of suspicious activity reports.

It added that the gambling regulator had not used enforcement powers in the period covered, lacks criteria for escalation to enforcement and “overly focuses on remedial actions and has legal impediments in sanctioning entities that withdraw their licences”.

The report’s only priority action for the AGCC said that it “should further enhance, with more effective testing, its monitoring of e-Casinos’ procedures and systems, particularly when it comes to the detection and scrutiny of unusual transactions, and it should rethink and clarify the circumstances under which it takes enforcement action”.

AGCC executive director Andrew Gellatly told Vixio that MONEYVAL’s generally positive review reflected the regulator’s efforts to more aggressively implement a risk-based approach to licensee compliance and work very closely with its 24 “eGambling” (B2C and B2B) licensees, hosting providers and service providers.

On areas needing improvement, Gellatly said the regulator has started adjusting certain practices as part of developing “what was acknowledged to be a very nuanced and detailed understanding of the sector’s … threats and vulnerabilities”.

On the AGCC “overly” focusing on remediation, he said: “Our remedial measures are themselves a form of sanctioning, and they are highly effective when implemented in near real time.

“Remediation plans being complied with can mean further escalation is not necessary and I think MONEYVAL's evaluation accepted this, but of course, it is not the only approach when viewed horizontally across other jurisdictions.”

Gellatly noted that “FATF standards do not require AML/CFT deficiencies to be fined”.

“Instead, sanctions must be available and used appropriately to improve compliance and we have the full range of sanctions at our disposal,” he said.

Responding to MONEYVAL’s criticism of few prosecutions and unclear procedure, Gellatly said: “Pecuniary fines are one way of enforcing compliance, but … we spend a great deal of time with our small group of operators, more so than most other regulators.

“We gather valuable information on a monthly and quarterly basis, and in our onsite inspections, which take place at least annually.

“As a result the relationship is collaborative and our operators appreciate and value us as a source of regulatory guidance. That is not something we plan to change.

“The consistency of contact allows us to correct any issues at the earliest opportunity and by small course changes made via remedial measures.”

Gellatly said Alderney comes out of the MONEYVAL review “very highly by any international comparison … . It was the last evaluation in the [Europe-wide] fifth round too, and expectations have certainly been raised during that process.”

Europe’s small, mostly UK-linked satellite regulators have not always had good press, especially when operator breaches have exposed technical and procedural weaknesses among limited staff.

But Gellatly said that the AGCC, now in its 25th year of operation, “has built a strong group of mature licensees and a sophisticated ecosystem of expertise in the Bailiwick that allows it to remain among the top tier of online gambling regulators globally".

“I think the evaluation team saw us as a well-resourced e-gambling regulator with a lot of expertise and a very full and very contemporary legislative framework which meets the technical standards set out in the FATF Recommendations.”

Still, all of this does not necessarily translate into aggressive expansion of clientele, especially in a maturing European market.

Improvement in regulatory standards, paradoxically, may repel the large volume of online gambling licensees elsewhere in the world that must now choose between regulatory stability, remoteness and taking their business into dark territory.

A tighter regulatory environment

When Philippine President Ferdinand Marcos Jr. announced last July that he would impose a ban on foreign-facing online gambling operators (POGOs), the scene was set for the migration of dozens of licensees to regulated or underground markets.

Former POGO licensees wanting to retain regulated status had to choose between the entrepreneurial clutch of smaller European regulators, a small number of Asia-Pacific would-be replacement destinations (Vanuatu, East Timor) or opportunist start-up regulators further afield (Anjouan).

Meanwhile, Dutch island dependency Curaçao is also undergoing reform of its notoriously opaque online gambling regulatory regime, suffering some uncertainty and likely loss of licensees in the process.

Standing in the way of any migration to Europe by POGOs and Curaçao refugees carrying potentially notorious baggage is the improvement in the reputations of the smaller regulators.

This is best illustrated by the recent MONEYVAL reports for Alderney and Jersey, which represent or approach best practice in Europe.

But notwithstanding acute reputational difficulties and the odd criminal scandal, the other three licensing hubs — Malta, Gibraltar and Isle of Man — are also on a trajectory of greater compliance and accountability to MONEYVAL and the Financial Action Task Force (FATF).

That has made compliance with European standards an increasingly difficult prospect for companies who established their business in an anything-goes, low-tax environment.

In the Philippines in particular, this amounted to ignoring regulations on illegal markets by the nation’s own regulator, high-level corruption, criminal infiltration and ultimately violence: extortion, mass kidnapping, torture and murder of employees and lower-level company officials.

In this regard, the attempt in November by a high-powered delegation of the digital affairs arm of the Isle of Man government to solicit “credible operators” among newly or soon-to-be unlicensed POGOs is noteworthy.

The trip brought to mind the halcyon days of POGO expansion before the Philippine government forced the centralisation of online gambling regulation.

In those days, Alderney, for example, was a regular on the Asian conference and expo circuit, probing for business in Macau when online gambling was not taboo.

Alderney has ceased this kind of Asian outreach, Gellatly told Vixio.

In contrast, news of last year’s trip by Digital Isle of Man CEO Lyle Wraxall to Manila irritated local businesses in the Isle of Man.

The mission, whose results have not been released to the public, was at best uncomfortably timed given ongoing Isle of Man investigations into two expelled licensees — King Gaming and Dalmine Limited — that were linked to China and likely associated immigration breaches.

The trip also came just days after the release of a dismal report by the United Nations Office on Drugs and Crime that savaged the Isle of Man’s online gambling environment and alleged licensee connections to Southeast Asian and Chinese organised crime.

However, the mission was apparently not associated with the Isle of Man’s Gambling Supervision Commission (GSC).

Instead, in recent times the commission has tightened its grip on licensees and ramped compliance awareness and monitoring amid the dual de-licensing scandal and ahead of the island’s upcoming MONEYVAL assessment.

The commission told Vixio at the time that it was “disappointed” by an “allusion to lax regulatory controls” in the UN report, and said the GSC “conducts its regulation in line with international standards”.

Malta and Gibraltar have also had their share of infamy in recent years, with Malta clashing with other European regulators and judiciaries over extra-territorial online gambling licensing and incompatible regulation. Operators on the island have also frequently been linked to organised crime in Italy and elsewhere.

The island nation continues to push boundaries — and raise eyebrows — after setting itself up as a backdoor for EU citizenship and as a haven for cryptocurrency and blockchain in finance and technology, in addition to regulated online gambling operations.

Malta strengthened its compliance credentials by getting off the FATF greylist in 2022 after improving on numerous compliance metrics. But based on the most recent assessments, Malta is lagging the five smaller online gambling jurisdictions in compliance terms.

Maltese corporate interests also consider Asia a viable market to promote new business and solicit licensees, with Taiwan’s biggest listed gaming company (International Games System, IGS) basing its key real-money-gambling TaDa Gaming subsidiaries in Malta amid a regulatory shift toward B2B licensing on the island.

At least one Maltese law firm is also shopping in gaming tech hub Taiwan for new clients seeking a less risky and more generous regulatory environment, and possible safe haven in the event of military conflict in the Taiwan Strait.

Gibraltar, meanwhile, escaped the FATF greylist this time last year, amid government commitment to more clarity in gambling regulation.

This is helping to offset years of perennial border difficulties with Spain, the long-term impact of point of consumption arrangements and the lingering effects of Brexit on the British territory.

Gibraltar’s MONEYVAL compliance ratings have also improved, now nominally equivalent to those of Guernsey/Alderney.

* B2B+B2C. Based on most recent published regulatory data. Includes some double counting of companies with multiple licences. Malta’s figure from its 2023 annual report does not include additional companies operating under umbrella corporate licences.
** NC: noncompliant, PC: partially compliant, LC: largely compliant, C: (fully) compliant 
          Sources: Jurisdiction gambling regulator websites and annual reports, MONEYVAL

Overall, the compliance environment in these five point-of-supply online gambling jurisdictions is bending toward tighter compliance and regional accountability, although Malta — by far the largest market in terms of licence numbers — is continuing to assert its differences with annoyed European mainlanders.

This shift towards tighter regulation is likely to dampen any remaining enthusiasm for European licence migration for the large number of Asian operators with skeletons in their closet or those fleeing Curaçao to avoid accountability.