Settlement Agreements and Warning Notices over 5 year period

Summary

The request sought statistics on settlement agreements and warning notices issued by the Isle of Man Gambling Supervision Commission between 2020 and 2025, including role breakdowns and publication policies. The authority disclosed that its settlement policy only began in June 2024, providing data for 2024 and 2025 while clarifying that warning notices are private matters not subject to public registers.

Key Facts

• The Gambling Supervision Commission (GSC) only introduced its settlement policy in June 2024, meaning no such agreements existed prior to that date.
• In 2024, the GSC entered into 2 settlement agreements with entities and 5 with individuals; in 2025, these figures were 2 and 13 respectively.
• Warning notices issued under settlement protocols totaled 5 in 2024 and 11 in 2025.
• The GSC considers warning notices to be private matters between the regulator and the individual, with no requirement for a public register or public statement.
• In 2025, 8 settlement agreements included provisions restricting individuals from performing controlled roles within GSC-licensed operators.

Data Disclosed

• June 2024
• 2024
• 2025
• 2 entities (2024)
• 5 individuals (2024)
• 2 entities (2025)
• 13 individuals (2025)
• 2 directors (2024)
• 4 directors (2025)
• 1 owner/controller (2024)
• 3 multiple roles (2024)
• 8 multiple roles (2025)
• 5 warning notices (2024)
• 11 warning notices (2025)
• 8 restricted role provisions (2025)

Original Request

Between December 2020 to December 2025, 1. How many settlement agreements were entered into by the Gambling Supervision Commission with individuals or entities in each year (this should include agreements of a similar nature under any other name)? 3. In each year, how many agreements related to persons acting as: - director - ultimate beneficial owner or controller - AML/CFT compliance officer - MLRO or deputy MLRO - multiple roles - other reasons 4. How many settlement agreements included a warning notice relating to the person being fit and proper and as an alternative to enforcement proceedings? 5. How many settlement agreement/warning notices included a provision that the person would not seek to perform any controlled role holder roles for a company licensed by the GSC or similar restriction? 6. Please provide a copy of GSC policy regarding publication to the general public or other regulators of settlement agreements and warning notices. This FOI does not relate to any settlement agreements entered into with GSC employees.

Data Tables (4)

Full Response Text

Ground Floor, St. Georges Court,
Myrtle Street, Douglas,
Isle of Man, IM1 1ED

Telephone: (01624) 694331 Fax: (01624) 694344 E-mail: gaming@gov.im
www.gov.im/gambling

Our ref: 5159989 6 January 2026

Dear xx xx

We write further to your request, received 10 December 2025, which states:

"Between December 2020 to December 2025,
1. How many settlement agreements were entered into by the Gambling Supervision Commission with individuals or entities in each year (this should include agreements of a similar nature under any other name)?

1. In each year, how many agreements related to persons acting as:
2. director
3. ultimate beneficial owner or controller
4. AML/CFT compliance officer
5. MLRO or deputy MLRO
6. multiple roles

7. other reasons

8. How many settlement agreements included a warning notice relating to the person being fit and proper and as an alternative to enforcement proceedings?

9. How many settlement agreement/warning notices included a provision that the person would not seek to perform any controlled role holder roles for a company licensed by the GSC or similar restriction?

10. Please provide a copy of GSC policy regarding publication to the general public or other regulators of settlement agreements and warning notices.

This FOI does not relate to any settlement agreements entered into with GSC employees."

Our response to your request is as follows:

1. The Gambling Supervision Commission (“GSC”) only introduced its settlement policy in June 2024. Since that date the GSC has entered into the following settlement agreements -

2024 2025 Entities 2 2 Individuals 5 13

1. In response to your request, the above agreements with individuals relate to them undertaking the following roles

2024 2025 Director 2 4 Owner/controller

1 AML/CFT Compliance Officer

MLRO or deputy MLRO

Multiple roles 3 8 Other reasons

Where recorded as ‘multiple roles’ this may include other stated defined roles listed in your request.

1. The number of warning notices issued using settlement protocols are detailed below. In terms of your request, we would note that a warning notice is not considered by the GSC to be an alternative to enforcement proceedings. You will note that the issuance of a warning notice is listed as one of the matters subject to the GSC’s ‘Decision-Making Process – Enforcement & Sanctions’ www.isleofmangsc.com/media/qsmhyjs4/decision-making-process.pdf

2024 2025 5 11

1. In considering settlement proposals specific to particular cases, the GSC has agreed to the inclusion of a clause in the respective settlement agreement whereby an individual agrees that, in addition to the imposition of a warning notice, that individual voluntarily undertake not to seek to perform a certain range of roles within any Operator licensed by the GSC for an agreed time period.

2024 2025 - 8

1. The GSC’s publication policy for enforcement matters is available on its website. For transparency we can advise that the issuance of a warning matter by a regulator is a private matter between the regulator and that individual. Unlike other powers available to the GSC (e.g. prohibition) the power to issue a warning notice does not come with an associated power to issue a public statement or a requirement to maintain a public register of persons who have been issued with a warning notice.

Please quote the reference number 5159989 in any future communications.

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I will now close your request as of this date.

Yours sincerely

xxx xxxxx