D1 Sanctions
Sanctions is not yet covered for this jurisdiction in this report.
Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.
Alderney is a sub-national cell of the Bailiwick of Guernsey with no independent AML/CFT statute; it is governed by Bailiwick-wide instruments (Sanctions (Bailiwick of Guernsey) Law 2018, Criminal Justice (Proceeds of Crime) Law 1999 Schedule 3) plus Alderney-specific overlays: the Alderney eGambling Ordinance 2009 (Schedule 4, AML/CFT/CFP for eCasinos, supervised by the Alderney Gambling Control Commission) and the Beneficial Ownership of Legal Persons (Alderney) Law 2017 (non-public BO register, Alderney Registrar).
Sanctions is not yet covered for this jurisdiction in this report.
Beneficial Ownership is not yet covered for this jurisdiction in this report.
The MONEYVAL/FATF Mutual Evaluation Report for Guernsey confirms that eCasinos operating under Alderney's eGambling framework are subject to AML/CFT obligations set out specifically in Schedule 4 of the Alderney eGambling Ordinance, 2009, a supervisory track distinct from the Bailiwick's general Financial Services Business Handbook regime applied to other financial services businesses. This structural separation is significant from an enabler-jurisdiction perspective: Alderney's eCasino sector sits under a bespoke, gambling-specific AML regime administered by the Alderney Gambling Control Commission, rather than being folded into the Bailiwick's general financial-services supervisory population.
This sector-specific track has now been actively amended. The Alderney eGambling (Amendment) Ordinance, 2025, confirmed in force by the States of Alderney's Billet d'Etat of 17 December 2025, resets the Schedule 4 customer due diligence trigger point, with the Ordinance's own record stating the purpose was to meet the 2025 FATF Methodology. This is read as a facilitator-side control tightening: the point at which a licensed eCasino operator must apply due diligence to a customer has been recalibrated, and secondary licensing-advisory commentary places the new trigger at a first deposit of EUR 3,000, although that specific figure has not been independently checked against the Commission's own consolidated Schedule 4 text this cycle.
The practical reading for enabler-jurisdiction analysis is that Alderney's eCasino licensing population functions as a discrete professional-facilitator class under its own AML supervisory track, and that track is demonstrably active in responding to evolving FATF standards rather than static. No new facilitator-type enforcement action was identified this cycle beyond the regulatory recalibration itself.
The open item for this domain is confirmation of the precise EUR 3,000 Schedule 4 threshold against the Alderney Gambling Control Commission's own primary text, since the current sourcing for that figure is secondary. Beyond that confirmation, no further enabler-jurisdiction development is presently on record for GG-ALD.
Conflict Finance is not yet covered for this jurisdiction in this report.
Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.
Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.
The standing AML/CTF regime of record for GG-ALD has been updated through the Alderney eGambling (Amendment) Ordinance, 2025, which came into force on 1 January 2026 as confirmed by the States of Alderney's Billet d'Etat of 17 December 2025. The amendment changes the trigger point for customer due diligence under Schedule 4 of the Alderney eGambling Ordinance, 2009, with the Ordinance's own legislative record stating that the purpose of the change is to meet the 2025 FATF Methodology. This is a baseline-descriptive update to an existing sector-specific regime rather than the creation of a new AML framework.
The MONEYVAL/FATF Mutual Evaluation Report for Guernsey independently confirms that eCasinos are subject to AML/CFT obligations set out in Schedule 4 of the Alderney eGambling Ordinance, establishing that this sector-specific regime is recognised in Guernsey's own mutual evaluation record, separate from the Bailiwick's general Financial Services Business Handbook framework. Secondary licensing-advisory sources place the newly reset customer due diligence trigger at a first deposit of EUR 3,000; this figure has not yet been cross-checked against the Commission's own consolidated Schedule 4 text, so while the fact and rationale of the change are confirmed by the primary legislative record, the precise quantum remains provisionally sourced.
At the parent-jurisdiction level, Guernsey is not identified by FATF as having strategic AML deficiencies, with its mutual evaluation report published 7 March 2025, a standing that GG-ALD inherits through the Bailiwick-wide framework without a distinct Alderney-specific listing. Guernsey's sanctions regime, which extends to Alderney as a Bailiwick-wide instrument, is understood to broadly mirror equivalent UK sanctions legislation, though this rests on legal-commentary corroboration rather than a primary legislative text reviewed this cycle. As a Crown Dependency outside the EEA, GG-ALD is not directly bound by the EU's AMLR, 6AMLD or AMLA framework.
The key item to watch is whether the Alderney Gambling Control Commission publishes or confirms its own consolidated Schedule 4 text reflecting the EUR 3,000 customer due diligence trigger, which would resolve the current reliance on secondary licensing-advisory sourcing for that figure. No further AML/CTF regime development is presently on record for GG-ALD beyond this amendment.
Commercial Activity is not yet covered for this jurisdiction in this report.
MLROs for Alderney-licensed eCasino operators should note that the applicable CDD trigger point has changed under the amended Schedule 4, with secondary sources indicating a first-deposit threshold of EUR 3,000, though that figure is not yet independently confirmed against the Commission's own text.
Compliance functions overseeing Alderney-licensed entities should treat the Schedule 4 track as its own sector-specific AML framework, now actively amended to track the 2025 FATF Methodology, rather than assuming parity with the general Bailiwick AML regime.
No material change for this persona this cycle
The Board should note that Guernsey is not FATF-listed as having strategic deficiencies and that Alderney's own eCasino regime is being proactively tightened, an enablement-side signal relevant to reputational and franchise-risk assessment for entities operating under the AGCC licence.
Technology functions supporting Alderney-licensed crypto-funding integrations should note that AGCC's tolerance of cryptocurrency as a funding method is discretionary and case-by-case, with no dedicated statutory crypto-AML text identified, resting on a single lower-tier source.
Risk functions should track the gap between the confirmed fact of the Schedule 4 trigger-point change and the as-yet-unconfirmed EUR 3,000 figure, treating the specific threshold as provisional pending primary-source confirmation from the Commission.
No material change for this persona this cycle
Audit should note this documented sourcing gap: the fact and FATF rationale of the Schedule 4 change are confirmed by the primary legislative record, but the specific threshold figure rests on secondary licensing-advisory sources pending independent verification.
The Schedule 4 customer due diligence trigger for Alderney eCasino licensees has been reset to align with the 2025 FATF Methodology, effective 1 January 2026.
Alderney's eCasino AML regime under Schedule 4 is confirmed as a distinct supervisory track from the Bailiwick's general Financial Services Business Handbook regime.
No material change this cycle.
Alderney's regulatory amendment and Guernsey's clean FATF standing together indicate a jurisdiction actively maintaining, not drifting from, its AML posture.
No primary AGCC policy text was located confirming crypto-specific AML controls for Alderney eCasino licensees.
The Schedule 4 CDD trigger reset is a confirmed regulatory change whose precise quantum remains provisionally sourced.
No material change this cycle.
The EUR 3,000 Schedule 4 CDD threshold figure has not been cross-checked against the Alderney Gambling Control Commission's own consolidated text this cycle.
Illustrative orientation only: as the EU AML Package moves from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities, under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly applicable AMLR (Reg (EU) 2024/1624) and per-state 6AMLD transposition, non-EEA sector-specific regimes such as Alderney's own Schedule 4 eCasino AML track could face growing pressure to demonstrate equivalence with EU supervisory standards where cross-border obliged entities interact with EU counterparties. This is an architecture-over-incident illustration of a possible structural dynamic, not an observed fact or a prediction about Alderney's regime specifically.
Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.
| Tracker | Status | Note |
|---|---|---|
| T1 · Russian Sanctions-Evasion Architecture | stable | No material change identified in sanctions-evasion channels affecting GG-ALD this cycle; exposure runs through the Bailiwick-wide Sanctions Act 2019 parent layer. |
| T2 · EU AML Package / AMLA | no_change | GG-ALD, as a Crown Dependency outside the EEA, is not directly bound by AMLR/6AMLD/AMLA; no transposition or equivalence development identified this cycle. |
| T3 · FATF Grey List | no_change | Guernsey (parent jurisdiction) is not on the FATF list of jurisdictions with strategic AML deficiencies; MER published 7 March 2025, predating this cycle. |
| T4 · Beneficial-Ownership Register Status | no_change | No GG-ALD-specific beneficial-ownership development identified this cycle; BO registration runs through the Guernsey Registry parent layer. |
| T5 · Crypto & Digital-Asset Integrity | stable | No GG-ALD-specific crypto/DeFi AML development identified this cycle; AGCC permits cryptocurrency discretionarily, case-by-case, with no dedicated statutory crypto-AML text located. |
| T6 · Sanctions Regime Divergence | stable | Guernsey (parent layer) automatically recognises and enforces UN, UK and EU sanctions under the Sanctions Act 2019; no GG-ALD-specific divergence identified this cycle. |