Correct. Technically nobody but MGM should be able to claim copyright on this, but they've never bothered with fan projects like films or games.
Nintendo got the rights to make an exclusive Bond game so Rare did it and released in 1997. After that, it was no longer exclusive and EA got the Bond rights for the videogames so they made The World Is Not Enough for N64, PS1, and handleds. EA kept the rights for 6 or 7 years releasing other Bond games until Activision got them to create the GoldenEye reboot released in 2010, but then they lost the rights after 007 Legends. Nobody else got the rights to make Bond games since then.
TL;DR: Nintendo, Rare, Activision, EA, Microsoft, or anybody related to the game industry doesn't own the GE or 007 rights, so we're safe in that matter. And even when they did own the rights (For the remake for example) we never got any problem with the development of this. And someone like GOG can't just "buy" the GE license since it's under Bond rights, which are owned by MGM.