Fit-and-Proper Assessment for Alberta iGaming: What AGLC Checks on Directors, Officers, and Key Persons

AGLC’s fit-and-proper review does not stop at the corporate applicant. The assessment reaches every director, officer, key employee, associate, and person with a financial interest in an affiliated entity. Compliance teams that scope their document preparation narrowly around the named registrant will arrive at the Due Diligence Unit materially unprepared. This guide sets out who must be assessed, the statutory grounds on which AGLC may refuse or revoke registration, the document set required, and the specific notification obligations that apply when key persons change during the registration period.

The Legal Foundation: Who Conducts the Assessment and Under What Authority

AGLC derives its authority to conduct background checks on individuals associated with an applicant from the Gaming, Liquor and Cannabis Act (Alberta) and the Gaming, Liquor and Cannabis Regulation (Alta Reg 143/1996). The SRIG, issued January 14, 2026, operationalises that authority through Subsection 2.4 and the surrounding provisions of Section 2. The SRIG is issued under the authority of the AGLC Board Chair and forms part of the conditions of registration for all iGaming Suppliers in Alberta, a category that encompasses both Registered Operators and registered Goods or Services Suppliers.

Alberta’s iGaming market operates as a regulated online lottery scheme under the Criminal Code (Canada), section 207. The iGaming Alberta Act, which received Royal Assent as Bill 48, establishes the Alberta iGaming Corporation (AiGC) as the entity that conducts and manages the scheme on behalf of the Crown. AGLC sits as the regulatory authority, and registration with AGLC is a precondition to any participation in the scheme. AGLC’s suitability assessment is not a commercial due diligence exercise. It is a statutory gatekeeping function with legal consequences for any individual or entity that fails it.

Who Is Assessed: Persons Covered by the Background Check Requirement

AGLC’s background check framework under SRIG Section 2.4 is framed around the applicant and all persons associated with the applicant. The SRIG provides detailed definitions of who falls within scope, and compliance teams should read those definitions against their actual corporate structure rather than assuming a narrow interpretation.

The SRIG defines a person as associated with an applicant to include any person who has a financial interest in the applicant, any officer or director of a corporation that is affiliated with the applicant, any person who controls a corporation affiliated with the applicant, and any relative of a person in either of those categories. The SRIG further specifies that a relative means any person connected by blood relationship, by adoption, by marriage, or by virtue of an adult relationship of interdependence.

A corporation is controlled by a person under the SRIG’s definitions if that person holds, directly or indirectly, more than 50 percent of the votes that may be cast to elect directors, or if that person has any direct or indirect influence that would result in control in fact. Two corporations are affiliated if one controls the other, or if both are controlled by the same person or group of persons. These definitions extend the assessment population significantly beyond the immediate applicant entity and its named officers.

“A personnel security screening process shall be in place for any director or officer, and any employee, agent or consultant, at a level that is appropriate for the individual’s role in the organization.”

The SRIG mirrors this standard directly from the AGCO Registrar’s Standards for Internet Gaming, which Ontario operators will recognise from their own registration process. In practice, operators with holding company structures, corporate parents in multiple jurisdictions, or a corporate group that includes gaming and non-gaming subsidiaries should map every entity that meets the affiliation test and identify every officer, director, and shareholder within scope before engaging the Due Diligence Unit.

What Does AGLC’s Fit-and-Proper Test Actually Assess?

SRIG Section 2.4 sets out the grounds on which AGLC may refuse registration where a person associated with the applicant meets any of the following criteria. These grounds apply not just to the corporate applicant but to any associated person within the definitions above.

AGLC may refuse registration where a person associated with the applicant has not acted, or may not act, in accordance with the law, with honesty and integrity, or in the public interest, having regard to that person’s past conduct. This is a broad, principles-based criterion that gives AGLC significant discretion to assess character across all available information, not merely formal convictions or regulatory sanctions.

A person associated with the applicant whose involvement would be a detriment to the integrity or lawful conduct of gaming activities or provincial lotteries constitutes a second ground. A third ground addresses reputational risk directly: where a person’s background, reputation, or associations may result in adverse publicity for the gaming industry in Alberta.

The SRIG then sets out three specific, time-bounded grounds. A person associated with the applicant who has, within the five years prior to application, contravened the Gaming, Liquor and Cannabis Act, the Gaming, Liquor and Cannabis Regulation, a predecessor of either, or any condition imposed on a registration under those instruments is a statutory ground for refusal. A person who fails to pass a records check as outlined in section 10(2) of the Gaming, Liquor and Cannabis Regulation is a further ground. Finally, where any licence or registration of the applicant, any of the applicant’s key employees, or any of the applicant’s associates has been cancelled or suspended by the issuing authority within the five years prior to application, AGLC may refuse.

The Document Set: What the Due Diligence Unit Requires

The AGLC Application Guide published at aglc.ca identifies the Due Diligence Unit as the first point of contact for all applicants. The Due Diligence Unit initiates the background check process, discusses the class of registration required under the Gaming, Liquor and Cannabis Regulation, and outlines the specific supporting documents required for each individual within scope. The document set is tailored to the applicant’s specific circumstances, which is why the Due Diligence Unit’s initial call is a prerequisite to document preparation rather than a formality.

Based on the SRIG and the Go-Live Compliance Guide (AGLC, January 2026), the document set for individuals within scope of the background check will typically include a personal history disclosure covering residential history, employment history, business interests, and financial circumstances. Source-of-funds documentation is required to establish the legitimate origin of any financial interest in the applicant entity. Criminal record checks are required for each individual, and AGLC’s engagement letter will specify the format and issuing authority acceptable for records from each relevant jurisdiction. Credit history documentation is assessed as part of the financial stability review, which evaluates whether the applicant has the financial resources to operate and whether associated persons present financial integrity concerns.

Prior licence disclosures across all jurisdictions where the individual has held, applied for, or been refused a gaming licence are a core component. The Go-Live Compliance Guide states explicitly that false or misleading statements may result in refusal or revocation of registration, which means the disclosure obligation extends to unfavourable history, not merely the licences currently held. AGLC staff will discuss the specific disclosure forms required for each individual during the Due Diligence engagement, as the format is not standardised across all applicant categories.

Role-Specific Scrutiny: Directors, C-Suite, Compliance, and AML Heads

The SRIG’s personnel security screening obligation is explicitly proportionate to each individual’s role. Scrutiny applied to a board director with no operational function in Alberta will not be identical to the scrutiny applied to the Chief Executive Officer, Chief Financial Officer, or the heads of compliance and AML. The latter group exercises direct operational control over systems and processes that determine whether Alberta’s regulatory framework is actually implemented, and AGLC’s Due Diligence Unit will assess those individuals with corresponding depth.

Role	Rationale for Assessment	Typical Scrutiny Depth
Board Directors	Governance oversight and potential control in fact over the applicant entity	Full background check, personal history disclosure, criminal record, prior licence history
CEO / Managing Director	Operational control, AGLC communications accountability	Full background check, source-of-funds, financial history, regulatory history across all jurisdictions
CFO / Finance Director	Financial integrity, financial resources of the applicant	Full background check, credit history, source-of-funds, financial declarations
Head of Compliance	Direct responsibility for SRIG implementation	Full background check, professional qualifications, regulatory history, integrity assessment
Head of AML / MLRO	FINTRAC obligations routed through AiGC, AML programme integrity	Full background check, professional qualifications, prior enforcement history
Key Employees (other)	Associated-person status under SRIG definitions, role-proportionate risk	Records check, personal history disclosure, role-specific documentation
Beneficial Owners with financial interest	Control in fact, financial integrity of the applicant	Full background check, source-of-funds, ownership structure documentation

For operators with Alberta-resident employees in compliance or AML roles, the due diligence process will engage the RCMP and provincial police systems for criminal record verification. For individuals ordinarily resident outside Canada, AGLC will require foreign criminal record checks from the relevant national authority, apostilled or legalised as applicable. Operators should factor in the lead time for obtaining foreign records when scheduling their Due Diligence engagement, as applications cannot advance until all required records are received and assessed.

The Three-Pronged Registration Process: Where Fit-and-Proper Sits

AGLC structures its registration process in three sequential stages. Fit-and-proper assessment occupies the first stage, conducted by the Due Diligence Unit, before any compliance or technical review begins. The second stage involves AGLC’s iGaming Compliance Branch, which reviews compliance documentation including the Go-Live Compliance Guide requirements, the Notification Matrix obligations, and gap analysis against the SRIG. The third stage is integration with AGLC’s centralised self-exclusion programme. Operators cannot advance to stages two or three while stage one remains open.

The Go-Live Compliance Guide confirms that due diligence disclosure forms are provided to applicants during the first stage engagement, with AGLC staff outlining the additional documents required based on the applicant’s specific corporate structure. The Guide states clearly that false or misleading statements may result in refusal or revocation of registration, and applicants are directed to provide accurate and complete information. This applies to individuals as well as to the corporate applicant.

AGLC’s assessment is not confined to what the applicant volunteers. The Due Diligence Unit conducts independent verification of all material disclosures, including verification of corporate ownership records, regulatory history across foreign jurisdictions, and personal history against law enforcement databases accessible through AGLC’s regulatory relationships.

What Triggers Re-Assessment During an Active Registration?

The fit-and-proper obligation does not end at registration. The SRIG and the Notification Matrix establish ongoing obligations that apply whenever the composition of key persons or the ownership structure of a registrant changes during the registration period.

The Go-Live Compliance Guide identifies the Due Diligence Unit’s dedicated email address, DueDiligence@aglc.ca, as the correct channel for all changes to ownership, financial interest, and key employees. This routing is separate from the iGaming Compliance Branch at iGamingCompliance@aglc.ca, which handles most other incident notifications and regulatory submissions. Routing a key-employee change to the wrong contact point does not discharge the notification obligation, and the distinction matters operationally for compliance teams that manage all AGLC correspondence through a single point of contact.

Mid-licence changes that will trigger engagement with the Due Diligence Unit include the appointment of a new director or officer, any change in the identity of a beneficial owner with a financial interest in the registrant, a change in corporate control that meets the SRIG’s definition (including indirect control through holding-company restructuring), and the appointment or change of any individual designated as a key employee for the purposes of the registration.

The SRIG also imposes a specific immediate notification obligation that sits alongside the general Due Diligence re-assessment process. Registered Operators and registered Goods or Services Suppliers must notify AGLC immediately when any officer, shareholder, director, or owner is charged with or convicted of an offence under the Criminal Code (Canada), the Excise Act (Canada), the Food and Drug Act (Canada), the Income Tax Act, the Proceeds of Crime and Terrorist Financing Act (Canada), foreign statutes substantially similar to any of those Acts, the Gaming, Liquor and Cannabis Act (Alberta), or the Gaming, Liquor and Cannabis Regulation (Alberta). The trigger is the charge or the conviction, not a final adjudication on the merits. The notification obligation applies regardless of whether the registrant believes the charge will ultimately succeed.

Objections to Registration: Process and Consequences

SRIG Section 2.5 addresses objections to a registration application. Where AGLC’s assessment raises concerns, the Board has authority to decline to grant registration. The enforcement framework under Section 2.6 establishes that where a violation of the Gaming, Liquor and Cannabis Act, the Gaming, Liquor and Cannabis Regulation, or Board policy has occurred, an inspector may prepare an Incident Report. That report is submitted to the Vice President, Regulatory Services Division, and a copy must be given to the registrant within 10 working days of the report being completed. The Vice President may refer the matter to the Board for a hearing.

Sanctions available to the Board include warnings, requirements to cease specific activities related to the violation, suspension or cancellation of registration, and financial penalties. An iGaming Supplier registration is automatically cancelled when a person sells, assigns, or otherwise transfers their registration interest, which is a further reason why any corporate restructuring involving a registered entity requires early engagement with the Due Diligence Unit rather than post-completion notification.

Operators who have previously operated in grey-market conditions in Alberta face specific risk. The SRIG requires registrants to cease all unregulated gaming activities in Alberta’s iGaming market where those activities would otherwise require registration. Prior unregulated conduct directed at Alberta residents is a matter that AGLC’s Due Diligence Unit will assess, and operators in that position should obtain legal advice before initiating a registration application to understand how prior conduct may bear on the suitability assessment.

Common Grounds for Difficulty in Assessment

Based on the SRIG’s stated refusal grounds and the broad scope of the associated-person definition, several categories of fact pattern create predictable assessment complexity. Operators should identify these against their own corporate history before engaging AGLC.

A licence cancellation or suspension anywhere in the world within the five-year look-back window is the most direct risk factor. This includes cancellations in unregulated or offshore jurisdictions, voluntary surrenders that occurred in circumstances involving compliance concerns, and suspensions that were subsequently lifted. The SRIG text covers “a foreign licence or registration of the applicant, any of the applicant’s key employees or any of the applicant’s associates,” which means that an individual key employee’s past regulatory history in another jurisdiction can engage the look-back ground even if the corporate applicant has a clean record.

Corporate structures that include holding companies, private equity investors, or family-office shareholders with financial interests in entities other than the direct applicant create extended associated-person populations. Each affiliated entity within the SRIG’s control and affiliation definitions adds directors and officers to the assessment scope. Operators should map this population before their first Due Diligence call and be prepared to provide documentation on individuals who may be several corporate layers removed from the Alberta operating entity.

Reputational associations, even without formal regulatory sanction, fall within the principles-based ground that allows AGLC to refuse registration where a person’s “background, reputation and associations may result in adverse publicity for the gaming industry in Alberta.” This is a discretionary assessment, and operators with individuals in scope who have been subject to significant adverse media coverage, parliamentary or congressional scrutiny, or civil litigation involving financial misconduct should take legal advice on how to address that history proactively in the disclosure package.

For operators also registered in Ontario, the AGCO Registrar’s Standards for Internet Gaming contain a materially similar personnel security screening obligation at standard 1.05, using language that mirrors the SRIG. Ontario and Alberta conduct entirely independent assessments. Clearance under the AGCO process does not transfer to Alberta, and the AGLC Due Diligence Unit will conduct its own independent verification regardless of an operator’s Ontario registration status. Our comparison of AGCO and AGLC requirements covers the structural differences between the two provincial regimes in detail. Operators who want to explore the full AGLC standards framework can also consult the AGLC Standards Explorer, which maps all 335 requirements across the SRIG’s five sections.

Practical Preparation: What Compliance Teams Should Do Before Engaging the Due Diligence Unit

Before placing the initial call to the AGLC Due Diligence Unit, compliance teams should complete a structured pre-engagement review. The review should produce a complete map of every person within scope of the associated-person definition under the SRIG: every director and officer of the applicant entity, every affiliated corporation within the control and affiliation definitions, every person with a financial interest in any such entity, and every relative within the SRIG’s relationship definitions where that relative has a relevant connection to the corporate structure.

Against that population map, compliance teams should then conduct a preliminary regulatory history review covering every jurisdiction where any in-scope individual holds or has held a gaming licence, has applied for a gaming licence, has had an application refused, or has been subject to any regulatory sanction. The five-year look-back is the hard statutory threshold, but AGLC’s broader character assessment may consider history beyond that window in applying the principles-based grounds. Providing a complete and accurate history from the outset is both a legal obligation and a practical advantage: disclosures identified by AGLC through its own verification, rather than volunteered by the applicant, will raise integrity concerns independently of whatever underlying fact triggered them.

Source-of-funds documentation for significant financial interests in the applicant entity should be prepared to a standard that demonstrates clean, traceable origins from identifiable commercial or investment activity. AGLC’s assessment in this area is functionally similar to the enhanced customer due diligence approach taken by AML-regulated entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), and operators whose corporate structures include offshore holding vehicles, trust arrangements, or nominee shareholding should expect detailed inquiry and should prepare documentation that addresses those arrangements directly. For a broader view of AML obligations in licensed iGaming markets, including FINTRAC transaction monitoring thresholds and suspicious transaction reporting frameworks, see the AML and Financial Compliance hub.

Operators seeking a broader view of Alberta’s full registration compliance programme, including go-live technical requirements, the SRIG’s 335 standards across five sections, and the SOC 2 and ATF certification obligations, can find that context in our overview of the AGLC SRIG framework.

Compliance officers advising clients on Alberta market entry should treat this assessment as a standing obligation, not a one-time clearance. The SRIG’s personnel security screening standard and the Notification Matrix’s change-reporting requirements together create a continuous suitability obligation that persists for the duration of the registration period. New appointments to the board, new beneficial owners following a fundraising round, and changes in key compliance or AML personnel all require proactive engagement with the Due Diligence Unit before or promptly after the change takes effect. Qualified legal counsel with experience in both Alberta gaming regulation and the relevant foreign jurisdictions should be engaged wherever any in-scope individual carries a complex regulatory or criminal history.

Key Resources

AGLC, Standards and Requirements for Internet Gaming (SRIG), issued January 14, 2026, signed under authority of the AGLC Board Chair. Available at aglc.ca/igaming. Section 2 (Regulatory Oversight) contains the background check, suitability, registration, and notification provisions directly cited in this article.

AGLC Application Guide for iGaming Registration, including the three-pronged registration approach, Due Diligence Unit engagement process, and the fee schedule. Available at aglc.ca/igaming, updated to July 3, 2026.

AGLC Internet Gaming Go-Live Compliance Guide (January 2026), which sets out the compliance document package requirements, the Notification Matrix, and the routing of key-employee changes to DueDiligence@aglc.ca.

Gaming, Liquor and Cannabis Act (Alberta, consolidated January 13, 2026), the primary enabling statute for AGLC’s registration authority. Available from the Alberta King’s Printer.

Gaming, Liquor and Cannabis Regulation (Alta Reg 143/1996, consolidated January 13, 2026), which includes section 10(2), the records check provision referenced in SRIG Section 2.4.

iGaming Alberta Act (Bill 48), which establishes AiGC and the legal structure of Alberta’s regulated online lottery scheme under Criminal Code (Canada) section 207.