AML Inspections Series Episode 11: Customer Sampling

Emma Shilling, Head of Compliance

The Isle of Man Gambling Supervision Commission (GSC) has released Episode 11 of its AML/CFT inspection series, titled Customer Sampling.

This instalment walks licence-holders through how inspectors assess customer file sampling and ensures compliance under the Code.

What the Webinar Covers

1. Customer Sampling Template

   1. A step-by-step guide to GSC’s template and how to present customer files in a clear, inspection-ready format.

2. Start of the Inspection Process

   1. What documents and customer data to prepare ahead of an onsite visit—expected formats, data scope, and typical file types requested.

3. What Information Is Requested

   1. Insights into how the GSC selects samples (typically high-risk or enhanced due diligence cases) and what supporting documents are required.

4. During the Onsite Inspection

   1. How inspectors review sampled cases with MLROs and Compliance Officers on site, ensuring customer journeys are documented and traceable.

5. Post‑Inspection Best Practices

   1. Guidance on how to respond to feedback or findings, updating documentation and addressing any gaps in case files.

Why Customer Sampling Matters

Episode 11 clarifies how the GSC evaluates whether the organisation's risk assessment, customer due diligence, and ongoing monitoring are well documented and consistently applied. The ability to produce coherent, well-organised customer samples demonstrates transparency, preparedness, and operational control.

Firms that prepare accurate, up-to-date files for inspection are better positioned to satisfy GSC data requests, manage scrutiny efficiently, and reduce regulatory risk.

What You Should Do Next

Watch the webinar	View on YouTube
Compile Updated Customer Files	Consolidate customer data, especially high-risk or EDD files and complete them using the GSC sampling template.
Pre‑Inspect Sample Cases	Run a quality review of selected files in advance, ensuring decision-making, escalation, and documentation are clearly evidenced.
Prepare Key Personnel	Ensure MLROs and Compliance Officers can effectively explain the rationale, risk assessment, and outcomes for sampled customers during onsite review.
Plan for Post-Inspection Actions	Have a remediation process ready to quickly address any feedback or documentation deficits uncovered during the inspection.

How SolutionsHub Can Help

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.

Reach out to us today for support on:

• Designing customer sampling frameworks using the official GSC template

• Review and gap analysis of high-risk and EDD customer files

• Mock sampling exercises and readiness drills

• Training for MLROs, Compliance Officers, and compliance staff on customer-record presentation and explanation

• Post-sampling improvement plans and documentation updates

Whether you're assembling sample files or preparing staff for detailed review, our team provides practical, risk-based solutions tailored to GSC inspection criteria.

Stay informed. Stay compliant. Stay ready.