What gets operators fined
4 red flags (2 high, 1 medium) and 0 controls that address them.
- high
MH DAO LLC or IBC used as the operating or holding entity for a gambling or 'Web3 Gaming' platform
FATF MER specifically flags DAO/Web3 Gaming structures as an ML/TF vulnerability given absent VASP-specific supervision.
Sources Available to subscribers - high
Operator or affiliate activity targeting MH-resident customers online
The prohibition is read by evaluators to extend to online gambling; s.404 criminal and daily civil penalties attach regardless of the operator's own licensing status elsewhere.
Sources Available to subscribers - medium
Gambling conducted aboard a vessel while within Marshall Islands territorial waters
FATF MER confirms the prohibition is read to reach cruise-ship gambling within territorial waters, a commonly overlooked exposure for the large MH open ship registry.
Sources Available to subscribers - critical
Any representation that an 'MH gaming licence' or 'MH gambling licence' exists
No licensing authority exists in the Marshall Islands for gaming or gambling; any such claim is categorically false and indicates fraud or misrepresentation.
Sources Available to subscribers
Worked scenarios
5 entry scenarios, each with the move we would make.
An offshore B2C online casino operator markets to MH-resident players via web and mobile.
The FATF MER reads the s.402 prohibition as extending to online gambling; there is no licence or registration pathway to legalise this activity for MH-resident customers.
Do this: Geo-block MH IP ranges and MH-issued identity documents; do not accept MH residents as customers.
Sources Available to subscribersA promoter proposes incorporating an MH IBC to act as the licence-holding entity for an online gambling brand.
MH issues no gambling licence of any kind; an MH IBC confers no gambling authorisation and the underlying activity remains prohibited if it reaches MH residents or is conducted from MH territory.
Do this: Reject any 'MH gaming licence' representation as false; treat as a critical red flag (MH-RF-001).
Sources Available to subscribersA DAO LLC registered in the Marshall Islands operates a decentralised 'Web3 Gaming' platform.
The FATF MER specifically identifies DAO structures used for Web3 Gaming as an ML/TF vulnerability given the absence of VASP-specific supervision in MH.
Do this: Apply enhanced AML/CFT diligence; do not treat MH DAO registration as a compliance substitute for gambling licensing anywhere.
Sources Available to subscribersA cruise operator flagged in the Marshall Islands' open ship registry offers casino gaming while transiting MH territorial waters.
The FATF MER confirms the prohibition is read to extend to gambling on cruise ships within territorial waters, distinct from flag-state registration questions.
Do this: Suspend onboard gaming operations while within MH territorial waters; confirm precise territorial-water boundaries with counsel before resuming.
Sources Available to subscribersA community group seeks to run a one-off charity bingo night.
This is the only lawful gambling-adjacent activity under MH law, conditional on obtaining a per-occasion permit from the appropriate local government council under s.403.
Do this: Apply for a local-council permit before the event; do not treat this as precedent for any recurring or commercial gambling activity.
Sources Available to subscribersWhat we looked for and could not find
Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.
Market opportunity. no credible GGR or market-size figure exists for a wholly prohibited, non-publishing jurisdiction; cannot estimate without inventing figures.
- searched: Marshall Islands gambling market size estimate
- searched: Marshall Islands GGR online gambling
- searched: Marshall Islands illegal gambling market study
- checked: fatf-gafi.org
Competitive landscape. no named-source figure for unlicensed market share; MER confirms zero casinos but offers no quantified illegal-market estimate.
- searched: Marshall Islands unlicensed gambling operators estimate
- searched: Marshall Islands offshore gambling websites residents
- searched: Marshall Islands illegal gambling enforcement statistics
- checked: fatf-gafi.org
Enforcement. no named, dated enforcement event (prosecution, closure, seizure) under s.404/s.405 was located in open sources during this run.
- searched: Marshall Islands gambling prosecution police
- searched: Marshall Islands illegal casino raid news
- searched: Marshall Islands gaming machine seizure police
- checked: rmiparliament.org
Data protection. no gambling-specific or general MH data-protection statute was identified within this gambling-focused research pass.
- searched: Marshall Islands data protection law
- searched: Marshall Islands privacy act
- searched: Marshall Islands personal data legislation
- checked: rmiparliament.org
Consumer protection. no general consumer-protection statute or regulator was identified and cross-checked for gambling application.
- searched: Marshall Islands consumer protection act
- searched: Marshall Islands consumer protection authority
- searched: Marshall Islands unfair trade practices law
- checked: rmiparliament.org
Source register
Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.
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