title: Ontario — Enforcement: How hard does the regulator enforce? | advennt.io canonical: https://advennt.io/jurisdictions/ontario/enforcement/ [Jurisdictions](https://advennt.io/jurisdictions/) [Ontario](https://advennt.io/jurisdictions/ontario/) Enforcement Ontario · Question 10 of 11 # Enforcement: How hard does the regulator enforce? Mixed · Confirmed · Not reviewed · changed since expert review · 4 post-review updates · Not reviewed · In expert review scope · [Back to full Ontario report →](https://advennt.io/jurisdictions/ontario/) Key section parameters | Jurisdiction | Ontario (CA-ON) | |---|---| | Regulator | Alcohol and Gaming Commission of Ontario (AGCO) / iGaming Ontario (iGO) | | Favourability | Mixed | | Confidence | Confirmed | | Review status | Not reviewed · changed since expert review · 4 post-review updates · Not reviewed · In expert review scope | | Last collected | 18 Oct 2026 | Summary answer There have been no prosecutions under the Criminal Code of non-local online gambling operators in Canada. The absence of such prosecutions illustrates the current attitude of law enforcement authorities towards non-local online gambling operations. The authorities have evinced no appetite to prosec… Not reviewed Information added after the 20 Aug 2026 expert review — published for currency and labelled not reviewed. 18 Oct 2026 Not reviewed AGCO issued its maximum available monetary penalty, C$200,000, against Score Media and Gaming Inc. (theScore Bet) on October 6, 2026, under Standard 4.07 of the Registrar's Standards for Internet Gaming, after the operator presented a player with cash-out offers it did not honour. AGCO's own release states that operators have a responsibility to ensure that the gaming opportunities they present are accurate and can be honoured as described. This is theScore Bet's second AGCO penalty within twelve months, following a reported C$105,000 penalty in October 2025 over alleged responsible-gambling failures tied to a high-volume patron, and it is the regulator's fourth registrant penalty identified since early August 2026, following an earlier C$100,000 fine against NorthStar Gaming in August 2026 for failing to apply its own enhanced due diligence obligations under Standards 6.02 and 6.03. The pattern across these actions, a maximum-available fine against a repeat registrant and a separate enhanced-due-diligence failure, together describe an enforcement posture that has intensified materially over this stretch, with recidivism and dual-layer AML compliance gaps as the two conditions most directly associated with penalty exposure on the current evidence. 11 Oct 2026 Not reviewed AGCO issued a C$200,000 monetary penalty order against Score Media and Gaming Inc. (theScore Bet) on 6 October 2026 for presenting two parlay cash-out offers that were not honoured, a breach of Standard 4.07 on misleading information. Press reporting describes this as the second-largest AGCO iGaming penalty since the 2022 market launch and the largest single-breach financial penalty the Registrar can levy under the current penalty schedule. It is also the fourth enforcement action against an iGaming registrant since early August 2026, following the C$70,000 penalty issued against supplier Booming Games in August 2026 for deploying a prohibited paid-spin autoplay feature that bypassed the required manual pause between wagers. Taken together, the two actions evidence AGCO testing compliance at both the player-facing representation layer (cash-out offers under Standard 4.07) and the underlying technical-configuration layer (autoplay functionality under the Standards governing certified game builds). The penalty schedule itself is a Registrar-set instrument and so remains subject to future revision by regulatory policy rather than by statute. The cadence of four actions in roughly two months marks a visible escalation in AGCO's enforcement posture against registrants and suppliers in this period. 28 Sep 2026 Not reviewed AGCO's enforcement position this period rests principally on a single reported action: press coverage states AGCO fined Relax Gaming Ltd. and Arrise Solutions Ltd. CAD $40,000 each after their games were found available on unregulated iGaming sites, despite those suppliers holding exclusive-supply registration to licensed Ontario platforms. The claim carries Uncertain confidence, sourced from a single Tier-4 outlet with no corroborating AGCO primary release retrieved this cycle, so it is best treated as a reported development pending confirmation. If accurate, it would mark an enforcement reach extending to B2B content suppliers whose games leak into the unregulated channel, rather than being confined to licensed B2C operators. Consistent with the common-law enforcement-theory framing, licence-breach liability under AGCO's Registrar's Standards for Internet Gaming remains the core exposure vector for any registered supplier or operator; the amended Standard 2.14 self-exclusion requirement and the new Ad Standards advertising complaint layer both create additional compliance surfaces that, if breached, would feed into this same licence-condition enforcement architecture. No other enforcement events were surfaced this cycle, and no AGCO primary enforcement register entry was retrieved to corroborate the reported supplier fines. 19 Sep 2026 Not reviewed Trade coverage characterises AGCO and iGaming Ontario as shifting emphasis from market onboarding toward compliance accountability in a now-mature Ontario iGaming market of more than fifty registered operators, applying public enforcement decisions and a progressive sanctions ladder to registered operators. This characterisation is Probable, sourced to a single trade-press account without independent T1 corroboration this cycle, and should be read as a directional posture signal rather than a confirmed enforcement-action count. A concrete forward enforcement-relevant marker exists in the player-protection space: AGCO has committed to revisiting the per-operator self-exclusion Standard 2.14 no more than twelve months after the Centralized Self-Exclusion Program launches. No new licensing, technical-compliance, or cross-border enforcement evidence emerged this cycle, and no such activity should be inferred from silence in those areas. ## Full section analysis There have been no prosecutions under the Criminal Code of non-local online gambling operators in Canada. The absence of such prosecutions illustrates the current attitude of law enforcement authorities towards non-local online gambling operations. The authorities have evinced no appetite to prosecute such activities, and this attitude has a significant bearing on the risk of prosecution of non-local online gambling operators that accept wagers from persons in Canada. Based upon the lack of reported cases, it would appear more likely than not that, the risk of prosecution is currently low. Indeed, the absence of prosecutions potentially indicates that law enforcement authorities view these activities as being outside their jurisdiction and beyond the purview of the Criminal Code. In 2016, the British Columbia gaming regulator (“GPEB”) sent letters to a number of non-local private operators, which accepted bets from persons in British Columbia, advising that they were conducting and managing gaming and betting operations contrary to the Criminal Code. This was an attempt by GPEB to embarrass and cow these operators into ceasing to accept bets from persons in British Columbia. Other than advising some of these operators’ non-Canadian regulators, no further steps have since been taken by GPEB following up on the allegations made against the non-local private operators in these letters. In the spring and summer of 2023, an organisation calling itself the Canadian Lottery Coalition (the “CLC”) operating through a private sector law firm sent letters (the “CLC Letters”) to a number of non-local private operators, asserting that by operating igaming websites that accepted persons in the ROC as customers, they were acting in violation of the Criminal Code. The original members of the CLC were the British Columbia Lottery Corporation, Alberta Gaming, Liquor and Cannabis Commission, the Atlantic Lottery Corporation, the Manitoba Liquor & Lotteries Corporation and Loto-Quebec. The CLC Letters also alleged that by advertising their igaming services in the ROC, the non-local private operators were contravening the Competition Act by making materially false or misleading representations concerning the legal status of the operators’ igaming activities. The CLC Letters further alleged that the non-local private operators were thereby causing significant harm to the members of the CLC and to their customers in the ROC. The CLC Letters demanded that the non-local private operators [i] cease making their igaming services accessible in the ROC, and [ii] cease all advertising activity in the ROC. In circumstances where the non-local private operators receiving the CLC Letters were also AGCO-registered igaming operators, the CLC Letters alleged that by offering igaming services in the ROC these operators were acting contrary to the Standards. In our view, this was a misconceived notion. There are no AGCO Standards that relate to the activities of an AGCO-registered igaming operator that take place in the ROC. As noted, the CLC Letters were sent by a private law firm acting as counsel for the CLC and not by a provincial law enforcement authority. At that time we wrote that this meant is was likely that if any legal remedies were actually going to be pursued in furtherance of the goals of the CLC, they would be of a civil nature rather than a criminal prosecution. This prediction was borne out in early February 2025, when the provincial gaming corporation of Manitoba (Manitoba Liquor & Lotteries [“MLL”]) applied to a Manitoba court on behalf of the CLC for an injunction to block the offshore online gaming operations of the corporation operating Bodog.eu and its associated free-play site, Bodog.net (collectively, “Bodog”) in Manitoba. The application sought to obtain the following relief from the Court: A declaration stating that Bodog has no lawful authority to offer gambling services in Manitoba or advertise those services within the province; A declaration stating that Bodog’s advertisements, with a particular focus on statements in those advertisements that characterize its platform as legitimate, legal, or safe, constitute misleading representations that contravene the federal Competition Act and Trademarks Act; A declaration stating that Bodog has engaged in tortious conduct by acting as an unauthorized and illegal gambling site in Manitoba; and An injunction against Bodog’s operations and advertising in Manitoba, which in addition to other measures would require Bodog to implement geolocation technology that would enable it to block Manitoba residents from accessing its platforms as required by the injunction. Bodog did not take any action to defend the matter or to dispute any of the allegations of MLL and the CLC. On May 26, 2025, the Court ruled in favour of MLL and the CLC. As a result, Bodog will not be permitted to advertise or accept players in Manitoba. How the Court plans to enforce that decision if Bodog were to choose not to voluntarily comply is not clear. It is important to note that this decision does not have precedential value from the perspective of whether the activities of Bodog (or any other operator) violate the Code or whether they would be within the criminal jurisdiction of the court, as this was not a criminal prosecution where the Court would have been required to apply a higher standard of proof. Even from a civil law perspective, the decision has little or no precedential value because Bodog did not contest the case. All efforts by provincial lottery corporations to exclude igaming operators from markets in the ROC have avoided any attempt to prosecute those operators under the Criminal Code. This leads us to conclude that the provincial governments have serious doubts as to whether such a prosecution would succeed, whether due to a defence based on jurisdictional issues as explained herein or other grounds.