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Financial Integrity Monitor

Guernsey — Alderney GG-ALD

Domains (D1–D6)
2
Sources
9
Role actions
8
Jurisdiction profile
CompliantTier BRisk: StableMixed

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).

MoreMONEYVAL's 5th-round MER (Dec 2024) rated the Bailiwick compliant/largely-compliant on all 40 FATF Recommendations and placed it in regular follow-up.

Key deficiencies
  • Alderney's beneficial ownership register remains non-public, accessible only to 'authorised entities' under the 2017 Law; full public/legitimate-interest access envisaged by the 2019 Crown Dependencies commitment is still being phased in via obliged-entity access only
  • MONEYVAL rated the Bailiwick's effectiveness in investigation and prosecution of money laundering as Low (the one failing Immediate Outcome out of eleven)
  • AGCC (Alderney's own eGambling regulator) publishes little independent enforcement data; the only substantive recent AML/CTF enforcement actions against Alderney-licensed eCasino operators have been taken by the UK Gambling Commission, a foreign regulator, rather than by AGCC itself
Recent developments (18m)
  • MONEYVAL adopted the Bailiwick's 5th-round Mutual Evaluation Report at its 68th Plenary (Strasbourg, 2-6 December 2024), rating sanctions implementation 'High' — one of only three jurisdictions globally alongside the UK and US
  • UK Gambling Commission settlement with Greentube Alderney Limited (9 January 2025): £1,000,000 payment in lieu of penalty for AML/CTF and social-responsibility control failings
  • Policy & Resources Committee policy letter P.2025/27 (25 February 2025) proposing an obliged-entity access regime to Guernsey/Alderney beneficial ownership registers, to be implemented by Ordinance during 2025
  • EU Delegated Regulation (EU) 2026/46 added Russia to the EU's AML high-risk third-country list with effect from 29 January 2026 — a listing that does not automatically transfer to the Bailiwick
  • Bailiwick-specific General Licence GY/RUSSIA/2026/GL1 issued 25 March 2026 under the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations 2020
Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Alderney's sector-specific eCasino anti-money-laundering regime has been actively amended to track the 2025 FATF Methodology. The Alderney eGambling (Amendment) Ordinance, 2025, confirmed in force by the States of Alderney's Billet d'Etat of 17 December 2025, resets the customer due diligence trigger point under Schedule 4 of the Alderney eGambling Ordinance, 2009, with the stated purpose of meeting the 2025 FATF Methodology. Secondary licensing-advisory commentary places the new trigger at a first deposit of EUR 3,000, though that specific figure has not been cross-checked against the Alderney Gambling Control Commission's own consolidated Schedule 4 text this cycle. The structural significance is that Schedule 4 operates as a distinct, sector-specific AML/CFT track for eCasinos, separate from the Bailiwick's general Financial Services Business Handbook regime, a separation the MONEYVAL/FATF Mutual Evaluation Report for Guernsey independently confirms.

Other Developments

Sector-specific supervisory architecture confirmed by mutual evaluation. The MONEYVAL Mutual Evaluation Report for Guernsey states plainly that eCasinos are subject to AML/CFT obligations set out in the Alderney eGambling Ordinance under Schedule 4, a track that sits apart from the general Bailiwick regime applicable to other financial services businesses. This confirms that the Alderney Gambling Control Commission functions as a sector-specific AML supervisor for eCasinos, operating alongside rather than subordinate to the Bailiwick's general financial-services AML framework.

Guernsey parent-layer standing unchanged. Guernsey, the parent jurisdiction for GG-ALD, is not identified by FATF as having strategic AML deficiencies, with its mutual evaluation report published 7 March 2025. GG-ALD inherits this standing through the Bailiwick-wide framework; no distinct listing status attaches to Alderney separately.

Cross-Monitor Connections

The Schedule 4 amendment and its FATF-alignment rationale connect directly to the gambling-regulatory monitor's own tracking of the same instrument, where the amendment is read as a licensing and player-protection matter; here it is read as an AML/CFT architecture matter, the same underlying legislative change viewed through the compliance lens rather than the licensing lens.

Outlook

The principal open question is whether the EUR 3,000 Schedule 4 threshold figure can be confirmed against the Alderney Gambling Control Commission's own primary text, since the figure currently rests on secondary licensing-advisory sources rather than the Commission's consolidated publication. Absent that confirmation, the precise mechanics of the new CDD trigger remain provisionally sourced even though the fact and FATF rationale of the change itself are confirmed by the primary legislative record.

weekly_brief_draft · JID GG-ALD
Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions and Professional Facilitators

Enabler Jurisdictions and Professional Facilitators

Continue reading

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.

Outlook

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.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto / Digital Assets / Financial Innovation

Not covered

Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

Continue reading

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.

Outlook

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.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon
No dated horizon items this cycle. 3 items tracked without a confirmed date.
3 pending date · baseline financial-integrity-2026-10-03
Role action cards
MLRO

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.

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.

2 evidence refs
Compliance

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.

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.

2 evidence refs
Legal

No material change this cycle.

No material change for this persona this cycle

Board

Alderney's regulatory amendment and Guernsey's clean FATF standing together indicate a jurisdiction actively maintaining, not drifting from, its AML posture.

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.

2 evidence refs
CTO

No primary AGCC policy text was located confirming crypto-specific AML controls for Alderney eCasino licensees.

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.

1 evidence refs
Risk

The Schedule 4 CDD trigger reset is a confirmed regulatory change whose precise quantum remains provisionally sourced.

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.

1 evidence refs
Operations

No material change this cycle.

No material change for this persona this cycle

Audit

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.

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.

1 evidence refs
Decision lens
MLRO

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.

Compliance

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.

Legal

No material change this cycle.

Board

Alderney's regulatory amendment and Guernsey's clean FATF standing together indicate a jurisdiction actively maintaining, not drifting from, its AML posture.

CTO

No primary AGCC policy text was located confirming crypto-specific AML controls for Alderney eCasino licensees.

Risk

The Schedule 4 CDD trigger reset is a confirmed regulatory change whose precise quantum remains provisionally sourced.

Operations

No material change this cycle.

Audit

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.

Shared evidence: 3 refs
Scenario sketches

AMLA transition and offshore eGambling AML supervisory tracks

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.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion ArchitecturestableNo 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 / AMLAno_changeGG-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 Listno_changeGuernsey (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 Statusno_changeNo GG-ALD-specific beneficial-ownership development identified this cycle; BO registration runs through the Guernsey Registry parent layer.
T5 · Crypto & Digital-Asset IntegritystableNo 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 DivergencestableGuernsey (parent layer) automatically recognises and enforces UN, UK and EU sanctions under the Sanctions Act 2019; no GG-ALD-specific divergence identified this cycle.
Registers

Enforcement actions

  • Following a section 116 regulatory review of Greentube Alderney's remote operating licence, the Commission found failings in AML/CTF and social-responsibility controls between September 2022 and June 2023, including delayed scrutiny of complex/unusual transactions and inadequate 'risky occupation' risk profiling. 9 Jan 2025
  • MONEYVAL adopted its 5th-round Mutual Evaluation Report on the Bailiwick at the 68th Plenary (Strasbourg, 2-6 Dec 2024), rating the Bailiwick compliant/largely-compliant on all 40 FATF Recommendations, with a 'High' effectiveness rating on targeted financial sanctions (one of only three jurisdictions globally, with the UK and US) but a 'Low' rating on ML investigation/prosecution. 6 Dec 2024
  • Policy letter P.2025/27 proposed amending the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law 1999 via Ordinance to grant 'obliged entities' (regulated financial services businesses) direct access to beneficial ownership registers for AML/CFT/CPF due-diligence purposes, aligning with EU Directive (EU) 2024/1640 direction (6AMLD) despite the Bailiwick's non-EU status. 25 Feb 2025
  • The Alderney eGambling (Proliferation Financing etc.) Regulations 2024 extended the AML/CFT obligations in eGambling Ordinance Schedule 4 to require licensees to consider targeted-financial-sanctions and proliferation-financing risk in business and customer risk assessments, ahead of the MONEYVAL on-site visit. 13 Mar 2024

Sanctions changes

  • The Policy & Resources Committee issued Bailiwick-specific General Licence GY/RUSSIA/2026/GL1 under the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations 2020, replicating (with minor domestic adaptation) a UK OFSI general licence permitting otherwise-prohibited activity under the Russia sanctions regime. 25 Mar 2026
  • The European Commission added Russia to the EU's AML high-risk third-country list via Delegated Regulation (EU) 2026/46, entering into force 29 January 2026 — a distinct listing mechanism from UN/UK/US sanctions. 29 Jan 2026
  • The Bailiwick implemented the UK's new 'Global Irregular Migration' sanctions regime via the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Amendment – Global Irregular Migration etc.) Regulations, 2025, extending a previously UK-only designation framework into Bailiwick domestic law. 1 Jan 2025

Regulatory horizon (register)

  • MONEYVAL regular follow-up report on 5th-round MER
  • Legitimate-interest access phase for BO registers
  • EU AMLR general application date affecting third-country counterparties

Active schemes

  • Alderney eGambling AML/CTF gatekeeping exposure
  • Non-public Alderney beneficial ownership register
  • CSP-mediated non-resident company formation pipeline
Sources
  1. States of Guernsey / Policy & Finance Committee of the States of Alderney
  2. MONEYVAL / FATF
  3. FATF
  4. European Commission (DG FISMA)
  5. States of Guernsey
  6. UK Gambling Commission
  7. States of Alderney
  8. States of Guernsey Policy & Resources Committee
  9. Elliptic
Coverage gaps
MONEYVAL's December 2024 MER rated the Bailiwick's effective…
MONEYVAL's December 2024 MER rated the Bailiwick's effectiveness in investigation and prosecution of money laundering as Low — the only failing Immediate Outcome of eleven — despite the Economic & Financial Crime Bureau's establishment as a dedicated ML-focused unit.
Alderney's Register of Beneficial Ownership remains closed t…
Alderney's Register of Beneficial Ownership remains closed to public inspection; only 'authorised entities' can access it, and the 2025 reform only extends access to AML/CFT obliged entities rather than the public or civil society.
No standalone, English-language, publicly searchable AGCC en…
No standalone, English-language, publicly searchable AGCC enforcement register (equivalent to the UK Gambling Commission's public register) could be located for Alderney-licensed eGambling operators; the most material recent AML/CTF enforcement findings against Alderney-incorporated operators (Greentube Alderney, Daub Alderney) were published exclusively by the UK Gambling Commission, a foreign regulator regulating only the GB-facing portion of these businesses.

Evidence

Confidence-tiered claims

Customer due diligence trigger point amended specifically to meet the 2025 FATF Methodology; secondary sources place the new trigger at a first deposit of EUR 3,000. SRC-fim-GG-ALD-001
Probable · 1 source
AGCC operates a sector-specific eCasino AML regime under Schedule 4 of the eGambling Ordinance, distinct from the Bailiwick's general Financial Services Business Handbook regime. SRC-fim-GG-ALD-002
Probable · 1 source
Guernsey's sanctions regime, which extends to Alderney as a Bailiwick-wide instrument, broadly mirrors equivalent UK sanctions legislation. SRC-fim-GG-ALD-003
Probable · 1 source
AGCC permits cryptocurrency as a funding method for licensees on a discretionary, case-by-case basis, with no dedicated statutory crypto-AML text located. SRC-fim-GG-ALD-006
Uncertain · 1 source
Guernsey is not identified by FATF as having strategic AML deficiencies; its mutual evaluation report (via MONEYVAL) was published 7 March 2025. SRC-fim-GG-ALD-005
Probable · 1 source