What Happened

Gambling enforcement in Canada operates almost entirely at the provincial level, with each province’s designated regulator holding jurisdiction over operators, venues, and related activities within its borders. There is no single federal gambling enforcement body, though the RCMP and provincial police may become involved when criminal conduct — fraud, organized crime, money laundering — is alleged.

This explainer focuses on administrative enforcement: the process by which provincial regulators investigate alleged regulatory violations and impose sanctions on licensed operators.

Why It Matters

Understanding enforcement mechanisms matters for several reasons. Industry observers, journalists, and policy analysts need a clear picture of what levers exist and how they are used. Consumers interacting with regulated operators benefit from knowing what recourse exists when something goes wrong. And policymakers assessing whether a regulatory framework is working require data on enforcement outcomes.

The typical enforcement cycle in a province like Ontario follows these broad stages:

1. Detection. Violations come to regulatory attention through multiple channels: consumer complaints submitted directly to the AGCO, internal compliance reviews and auditing, reports from iGaming Ontario under its operating agreements, whistleblower disclosures, and proactive monitoring of advertising and digital activity by regulator staff.

2. Preliminary assessment. The regulator reviews information to determine whether it warrants a formal investigation. Many complaints are resolved informally or do not disclose a regulatory violation.

3. Investigation. For substantive potential violations, a formal investigation commences. Investigators may request documents from the operator, interview witnesses, and examine technical records. Operators are legally required to cooperate with regulatory investigations as a condition of their licence or registration.

4. Notice and opportunity to respond. Before any adverse decision, the operator is typically entitled to notice of the alleged violation and an opportunity to make submissions. This procedural fairness requirement is embedded in administrative law principles that apply to all provincial regulators.

5. Decision. The regulator issues a written decision setting out findings and, if a violation is found, imposing sanctions. Sanctions range from compliance directives (requiring specific remedial action) through monetary penalties to suspension or revocation of a licence.

6. Appeal. Operators generally have a right to appeal adverse decisions, typically to a designated appeal body or tribunal. In Ontario, the Licence Appeal Tribunal handles certain AGCO decisions.

Penalty Ranges

Reported penalty amounts in Ontario have varied widely depending on severity. The AGCO’s published enforcement outcomes — which the regulator posts on its website as a transparency measure — show penalties ranging from modest fines for first-time or minor infractions to more substantial amounts for repeat or serious violations. The precise penalty framework is set out in the Gaming Control Act and accompanying regulations.

It is worth noting that the AGCO’s published enforcement record covers primarily the regulated private market launched in 2022. Prior enforcement focused on unlicensed operators and illegal gaming venues, a distinct regulatory context.

Offshore and Grey Market Operators

A persistent challenge for Canadian gambling regulators is enforcement against offshore operators serving Canadian consumers without regulatory authorization. The Criminal Code framework creates legal risk for such operators, but enforcement against entities with no Canadian presence and no assets in Canada is practically difficult. Regulators have pursued some enforcement through payment processor blocking and internet service provider filtering — tools that have had mixed documented effectiveness.

What’s Next

Questions about enforcement capacity — whether provincial regulators have sufficient resources and legal tools to effectively police an increasingly complex digital market — are actively debated. Proposals have included expanded financial intelligence sharing between gaming regulators and anti-money laundering authorities, stronger data-sharing frameworks, and clearer interoperability between provincial regulatory databases. The adequacy of current enforcement against affiliate marketing practices, where violations may be less visible, is also a topic of ongoing policy discussion.

Sources