Gibraltar Regulator’s Email Raises Serious Red Flags

I asked GPT for a second opinion on Andrew Lyman’s circulating email to Walter Finch from The Olive Press. The result? A surgical breakdown of why it doesn’t add up and why it might say more about Gibraltar’s regulatory culture than anyone intended.👇 Here my question:

“What do you think about this email from Mr. Andrew Lyman to Walter Finch from The Olive Press, is it believable and does it make any sense to you? The email sounds really off to me, but I can’t exactly pinpoint what's wrong with it. I'm not too sure about Isolas never taking any control or so, as they (and Hassans) control everything in Gibraltar…”

🔍 1. Self-justifying tone and defensiveness

Lyman’s email reads less like a professional, regulator-to-journalist response and more like a legal defence statement. The language is overly reactive, which undermines its credibility. A regulator should not be this personally invested in distancing themselves from a case unless something has triggered a reputational concern.

🧩 2. Contradictory logic about timing and jurisdiction

·         He states that he only received “outline allegations” in November 2023, but already knew they were “high-level, ambiguous and inconsistent.” How could he assess them so confidently without specifics?

·         He claims some issues predated his tenure starting in 2018, but if the alleged conduct was during 2020–2022 (which includes the £850k AML fine), that excuse doesn't hold water.

·         Saying he lacks “standing” to investigate because the licence was surrendered is legally and regulatory questionable. Authorities often retain powers over past licence holders, particularly regarding serious misconduct.

⚖️ 3. Shifting responsibility to the courts

·         Lyman implies it's not his role to evaluate the substance of allegations if they are involved in civil proceedings. That's not how regulatory enforcement works. Courts and regulators have distinct and independent functions.

·         Regulators are not supposed to wait for court findings to act, especially on AML, licensing breaches or corporate governance.

🏛️ 4. Implausible minimisation of Minister-Isolas link

He says:

“…the former Minister never sought to control or influence the conduct and outcome of the anti-money laundering investigation…”

But this seems irrelevant unless:

·         Someone did try to exert pressure.

·         Or there was at least reasonable concern that they could.

Also, calling the Minister’s ties to Isolas “self-evident and transparent” doesn’t make them less problematic, quite the opposite. Gibraltar’s size and power concentration make it essential for regulators to overcompensate on independence, not dismiss it.

🧨 5. Mischaracterising motive: ‘bounced into an investigation’

·         Lyman frames the situation as if Manasco or his legal team were trying to “bounce” him into opening an investigation. That’s a strangely hostile interpretation.

·         A more neutral framing would have been: “I evaluated whether the allegations warranted regulatory review and requested further documentation.” Instead, he suggests bad faith, a red flag of regulatory bias or deflection.

🕳️ 6. What’s missing?

·         No comment on who conducted the AML investigation and whether Isolas or Hassans were in any way involved or consulted.

·         No acknowledgement of how allegations were logged or escalated (e.g., internal protocols).

·         No recognition of the broader regulatory reputational risk, even though Mansion’s collapse and alleged misconduct had cross-border impact.

🎭 7. “The former Minister is someone of high integrity…”

This is eyebrow-raising. Regulators should avoid personal character assessments in official communications. Statements like these feel more personal than procedural, and carry the tone of someone protecting an insider network.

⚠️ Final judgment

This email lacks:

·         Professional distance

·         Regulatory clarity

·         Logical consistency

And it adds:

·         Defensiveness

·         Implausible minimisation

·         Poor institutional framing

You’re right to flag that it doesn’t feel right. It's dressed in formal language but reveals a system that’s both insecure and conflicted.

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Here you can find Mr Lyman’s email to The Olive Press: https://www.theolivepress.es/spain-news/2024/07/27/exclusive-gibraltars-gambling-commissioner-tells-the-olive-press-there-was-no-conflict-of-interest-in-his-decision-not-to-investigate-maligned-gaming-company-mansion/