The Alcohol and Gaming Commission of Ontario concluded the first half of 2024 with a notable enforcement record in the iGaming sector. Between January and June 2024, AGCO issued nine compliance notices to registered internet gaming operators and initiated formal proceedings that resulted in two licence suspensions. The actions represent the most active six-month enforcement period since the competitive market launched in April 2022.
AGCO's enforcement activity in the iGaming space draws its authority primarily from the Gaming Control Act, 1992 (Ontario), which grants the Registrar broad powers to investigate, impose conditions, suspend, and ultimately revoke registrations held by gaming operators. The Act also provides for monetary penalties, though AGCO's practice has been to focus enforcement remedies on operational changes and — in serious cases — suspension rather than fines alone.
Advertising Violations
The largest category of enforcement action in H1 2024 was advertising standard breaches, which accounted for five of the nine compliance notices issued. The violations fell into several sub-categories. Three notices were issued for bonus disclosure failures, where operators or their affiliate partners promoted offers without adequately disclosing material wagering requirements, expiry dates, or eligibility restrictions. Two notices were issued for celebrity endorsement violations involving individuals whose appearance in marketing materials raised concerns about the AGCO's requirement that endorsers be 25 years of age or older.
One of the bonus disclosure cases involved a promotional email campaign that described a deposit match offer using headline language that did not reflect the conditions attached to the bonus. The email's subject line and hero image featured a large bonus value that was subject to a 35x wagering requirement not disclosed until the fourth paragraph of the accompanying terms. AGCO's compliance team identified the email through its ongoing monitoring program and issued a compliance notice requiring immediate withdrawal of the campaign and retraining of the operator's marketing compliance team.
KYC Non-Compliance
Two compliance notices were issued for Know Your Customer (KYC) deficiencies. KYC requirements under AGCO's standards mandate that operators verify player identities at registration, conduct ongoing monitoring of account activity for indicators of fraud or money laundering, and implement enhanced due diligence for accounts exhibiting unusual patterns.
In both cases, AGCO's review found that operators had permitted accounts to reach elevated wager volumes without completing required enhanced verification checks. The notices required both operators to implement corrective procedures, conduct retroactive reviews of affected accounts, and report completion of remedial actions to AGCO within 60 days.
Responsible Gambling Program Gaps
Two of the nine compliance notices addressed deficiencies in responsible gambling programs. The standards require operators to implement a suite of responsible gambling tools including mandatory deposit limits at account registration, cooling-off periods, reality checks during gameplay sessions, and integration with the iGaming Self-Exclusion (iGAS) register. One operator was found to have implemented a configuration that, under certain account settings, allowed players to bypass the mandatory reality check interval. The other notice addressed a technical failure in the iGAS integration that, during a period of approximately two weeks, did not correctly screen new account registrations against the exclusion register.
The Two Licence Suspensions
The two licence suspensions issued in the first half of 2024 represented a significant escalation of AGCO's enforcement posture. Consistent with AGCO's practice at the time of formal proceedings, the names of the operators are not identified in this report pending the conclusion of any appeal or review processes. AGCO's public enforcement register provides updated status information as proceedings are concluded.
The first suspension was triggered by a combination of factors including repeated advertising breaches following a prior compliance notice, failure to complete required remedial actions within the specified timeframe, and evidence of inadequate internal compliance governance. The cumulative nature of the non-compliance — rather than any single egregious breach — was the stated basis for escalating to suspension rather than issuing a further compliance notice.
The second suspension arose from a finding of material KYC non-compliance combined with evidence that the operator had not accurately represented its compliance status in mandatory self-reporting to AGCO. Providing inaccurate information in regulatory filings is treated with particular seriousness by AGCO and was the primary factor in the decision to suspend rather than impose a further compliance condition.
Industry Reaction and AGCO's H2 Priorities
Industry participants generally acknowledged the enforcement uptick as an expected development in a maturing regulated market. Compliance professionals at several operators noted that AGCO's monitoring capabilities have become more sophisticated over time, enabling earlier detection of issues that might previously have gone unnoticed.
AGCO has publicly stated that its enforcement priorities for the second half of 2024 will focus on affiliate marketing compliance, following observations that some third-party affiliates promoting Ontario-registered operators have been operating outside the advertising standards framework. The regulator has clarified that operators bear responsibility for affiliate conduct and that AGCO will treat affiliate non-compliance as an operator registration matter.
The FY 2024 enforcement record also reflects AGCO's stated intention to publish more detailed compliance guidance — both to help operators understand expectations more precisely and to ensure that enforcement actions can be grounded in clear, publicly accessible standards. A revised compliance guide is expected in Q3 2024.