AML Inspections Series Episode 10: Compliance Culture

Emma Shilling, Head of Compliance

The Gambling Supervision Commission (“GSC”) continues its AML/CFT Inspection Webinar series with Episode 10, dedicated to Compliance Culture.

This webinar was released on 14 July 2025 and addresses the cultural and practical foundations of effective compliance programmes.

What the Webinar Covers

1. Procedures and Controls

   1. Establishing clear, accessible policies and procedures

   2. Demonstrating consistent application of AML/CFT measures across the business

2. Monitoring and Testing Compliance

   1. Performing regular internal reviews and testing

   2. Using monitoring mechanisms to detect issues early and act proportionately

3. Foreign Branches & Subsidiaries

   1. Ensuring consistent compliance across wider organisational structures

   2. Identifying jurisdiction-specific risks and harmonising practices

4. Whistleblowing Policies

   1. Embedding robust mechanisms for confidential reporting

   2. Promoting a speak-up culture supported by clear protection protocols

5. New & Emerging Typologies

   1. Updating staff awareness of evolving threats and typologies

   2. Integrating typology intelligence into daily routines and risk assessments

Why Compliance Culture Matters

A strong compliance culture goes beyond formal AML systems. It reflects the attitudes and behaviour of all staff. This episode demonstrates how inspectors assess not only policies, but also whether staff genuinely understand, apply, and report effectively on regulatory obligations. Such insight aligns with the demands of both the Gambling (AML/CFT) Code 2019 and broader corporate responsibility expectations.

Operators that embed a proactive compliance culture are better positioned to identify risks early, adapt to new threats, and reduce regulatory exposures.

What You Should Do Next

Watch the Episode	View on YouTube
Assess Your Policies & Controls	Are your compliance procedures well documented, accessible, and regularly reviewed? Evaluate how they are applied in practice.
Review Your Testing & Monitoring	Do you conduct internal audits or spot-checks? How effective are your challenge and escalation pathways?
Check Subsidiary Oversight	If operating across jurisdictions, ensure the same compliance culture is upheld across your organisational structure.
Evaluate Your Reporting Channels	Is your whistleblowing process well-publicised and trusted? Do staff understand how to report concerns confidentially?
Stay Ahead of Typology Trends	Make sure your team refreshes their understanding of emerging typologies and updates training accordingly.

How SolutionsHub Can Help

At SolutionsHub, we assist Isle of Man licence-holders in translating regulatory expectations into actionable, sustainable frameworks.

Our team works with some of the most innovative gambling operators on the Isle of Man and beyond, helping to turn complex regulatory challenges into clear, actionable strategies.

Our services include:

• Culture diagnostics and gap analyses

• Monitoring and testing programme design

• Whistleblowing policy development

• Role‑based training and typology awareness sessions

• Readiness support for GSC inspections and internal audits

Stay informed. Stay compliant. Stay competitive.