23 March 2026: Civil Penalties Guidance Stakeholder Engagement
What civil penalty provisions is the GSC seeking feedback on?
The GSC is inviting stakeholder feedback on two draft documents:
- The Gambling (Civil Penalties) Regulations 2026; and
- The new civil penalty guidance for individuals will operate alongside the Regulations.
What are the draft Gambling (Civil Penalty) Regulations?
The draft Regulations are intended to be made following amendments to section 22 of the Gambling (Anti‑Money Laundering and Countering the Financing of Terrorism) Act 2018, brought about by the Gambling Legislation (Amendment) Bill 2025.
These Regulations set out the framework for how the GSC may impose civil penalties on operators and relevant individuals. They address three areas:
- The maximum civil penalty that may be imposed on an operator or individual;
- The factors the GSC must consider on a case‑by‑case basis when determining the amount of a civil penalty; and
- The process the GSC must follow once it has made a decision to impose a civil penalty, including notice and appeal requirements.
What is the civil penalty guidance for individuals?
Currently, civil penalties may only be imposed on an operator.
The Gambling Legislation (Amendment) Bill 2025 expands this power so that a civil penalty may also be imposed on certain individuals (specifically “controllers”, “key persons” and “senior managers”), where an AML/CFT contravention by the operator is attributable to that individual’s consent, connivance, or negligence.
The new guidance explains how the GSC will apply this extended power, including:
- How it assesses individual responsibility;
- Examples of how “consent”, “connivance” and “negligence” may arise;
- How penalties will be calculated; and
- How the decision‑making process will operate in practice.
This guidance is separate from, and complementary to, the operator-focused discretionary civil penalty guidance already in effect.
Have your say
The GSC is committed to carefully considering all feedback received during this engagement exercise and will make adjustments to the draft guidance where appropriate and practicable.
The GSC will also be hosting an online Q&A session to support stakeholders in understanding the draft regulations and guidance, and for any further discussion in person. Full details, including the date, time and joining instructions, will be published in due course.
Once the consultation has concluded, the GSC will publish a further document summarising the responses received and outlining any changes made to the regulations and guidance as a result.
Responding to this consultation and questions
You can respond by downloading a .PDF version of the draft guidance and submitting your comments via this form, or by emailing Consultations.GSC@gov.im
How long will we be seeking feedback
We will be seeking feedback on the draft Gambling (Civil Penalty) Regulations and associated guidance for individuals for the period starting 23 March 2026 to 25 May 2026.