27 January 2025: Terrorist Financing Awareness Session

Last week, GSC staff members attended a government-focused awareness session on Countering the Financing of Terrorism (CFT) in the Isle of Man. The session featured insightful presentations by expert speakers from the National Terrorist Financial Investigation Unit (NTFIU) and the Charity Commission for England and Wales which focussed on combatting the international threat of Terrorist Financing (TF).  A session was also held the previous day on the same topic for industry and members of the public.


The Key themes of the session included:

  • Maximising data sharing through collaboration; and
    Communication and Outreach.
  • The speakers shared in-depth and emerging typologies with attendees from the public sector to boost a shared understanding of what regulators should be looking out for in the data we have access to but also to raise wider awareness.

Dare to Share

Emphasis was also placed on the necessity for cooperation between the public and private sectors through public-private partnerships.  A key message was to "dare to share" with law enforcement, working closely with other authorities to combat TF effectively.  Sharing data between agencies was a key element of the presentation as low-value low sophistication TF can be very hard to identify.

The presenters highlighted case studies in which data from Suspicious Activity Reports (SARs) led to the prevention of Terrorist acts within the UK – highlighting the importance of information sharing.

As a top-tier regulator, the GSC is committed to both national and international cooperation - sharing expertise with other agencies on the Isle of Man and beyond. Collaboration and active communication are essential to combatting the threat of TF on an international scale.

The GSC would like to take this opportunity to reiterate that SARs submitted by Operators could be the 'missing link' in cases of ML/TF/PF, helping to enhance existing data.

Ensuring front-line staff have an understanding of indicators and know how to escalate any concerns can help to combat ML/TF/PF on an international scale.  Although TF does not have known or prevalent typologies in the Gambling/eGaming sector, this does not remove the potential of ‘legitimate’ funds flowing through the gambling sector before being used for the financing of terrorism.

Risk assessments, training and awareness alongside effective reporting systems are key to understanding how a gambling business could be at risk of facilitating TF activity.

High-risk flags could include individuals receiving funds from crowdfunding or other donation-based platforms, individuals resident in an area with a high terrorist threat or in a neighbouring jurisdiction.  This could be considered alongside the use of verticals that could facilitate peer-to-peer transfers especially where it is possible to facilitate cross-border movement of funds.

Additionally, there are known risks around legitimate businesses being used to generate funds for terrorism and consideration of risk when engaging with third parties could include-

  • Business partnerships with links to designated individuals or organisations, screening third parties and suppliers may flag associations;
  • Geographic/Nationality risks linked to beneficial ownership should be identified and form part of any risk considerations; or
  • Involvement or associations with overseas NPOs operating in or offering aid to high-risk geographic areas.

Employees may become aware of a risk flag within their own operations that may give rise to concerns which are being minimised or ignored for instance-

  • Internal investment, changes of beneficial ownership or flags around existing beneficial ownership which may indicate that funds are being used to support terrorism;
  • Business partnerships in areas of high risk of terrorism; or
  • Support of non-regulated or foreign NPOs where there is minimal oversight and the activity is in higher risk jurisdictions.

Where an employee believes that a breach of regulatory requirements or criminal activity is taking place then they can make a protected disclosure to the regulator or another prescribed person as set out in the Public Interest Disclosure (Prescribed Persons) Order 2021.  The GSC and other authorities will handle such reports confidentially and anyone making such a report is afforded protection under the law from any reprisals.

An international Approach

Awareness sessions like this help us stay abreast of emerging typologies in the gambling sector and fulfil our objectives to keep the gambling industry crime-free and protect those at risk from bad actors. Threats of ML/TF/PF are constantly evolving and the GSC is committed to an agile approach in combatting financial crime. In spreading awareness of threats like TF, we can hope to address emerging challenges through collaborative supervision.

For more information on Terrorist Financing, a factsheet is available on the AML/CFT information page of our website. 

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