Rotten Rock – Part 7: Should Gibraltar be sanctioned?

A case for external intervention when internal boundaries collapse!

Gibraltar is no stranger to scrutiny. But what happens when scrutiny leads to silence, when oversight becomes overlap and when governance begins to resemble something closer to choreography than regulation?

Across the six parts of this investigative series, Malta-Media has examined how Gibraltar's political, legal and regulatory systems have allowed Mansion Group and its successors to operate within a permissive framework, often without meaningful consequence.

In this final part, we ask the unavoidable question: should external bodies now step in? Should Gibraltar be sanctioned? It's a provocative headline. But for those watching closely, not an unreasonable one.

The hallmarks of regulatory capture

Across dozens of court documents, affidavits and filings, a picture has emerged. It shows a structure where the regulators were appointed by the same ministers whose law firms advised licensees. Where the Financial Services Commission waved through licences, even as concerns about opaque ownership and grey-market revenues were mounting.

And where the judiciary, meant to be independent, issued sweeping freezing orders without open hearings, while declining to consider evidence of procedural irregularities and conflict.

This isn’t about individual wrongdoing. It’s about institutional enablers.

From Albert Isola’s simultaneous role as Minister for Financial Services and partner at ISOLAS LLP, to Andrew Lyman’s refusal to open a regulatory inquiry despite multiple red flags, the signs are plain. The regulator and the promoter are not just neighbours. In some cases, they are the same office.

Greylisting isn’t about punishment. It’s about credibility.

The Financial Action Task Force (FATF), GRECO and the European Commission don’t typically sanction small jurisdictions because of one rogue company. They act when patterns emerge. When questions are raised about systemic due diligence, beneficial ownership transparency or enforcement consistency and those questions are met with silence or spin.

Gibraltar was previously removed from the FATF’s watchlist in 2023 after committing to stronger oversight of virtual assets and company service providers. But the Mansion case undermines much of that progress.

Take for example the use of successor entities like Hermes, Apollo and Violet Star. All appear in documents reviewed during the litigation involving former Mansion CEO Karel Manasco. These companies allegedly absorbed functions previously held within Mansion, including staff payroll and service delivery, but under new names and without new scrutiny.

No statements were issued by the regulator. No compliance bulletins were circulated. The entities changed, but the ecosystem remained intact.

Time to talk greylisting?

Let’s talk about consequences.

When a jurisdiction exhibits long-term symptoms of weak enforcement, poor regulatory independence and political entanglement, global bodies start paying attention. Not because they want to punish, but because they need to protect financial stability and cross-border integrity.

The Financial Action Task Force (FATF), for example, evaluates jurisdictions on precisely these dimensions.

Independence of supervision. Risk-based enforcement. Transparency around beneficial ownership. Cooperation with foreign regulators. Gibraltar, on paper, checks many of these boxes.

But in practice?

• Beneficial ownership records are difficult to verify and were scaled back after the ECJ ruling.
• Enforcement action against gambling operators is virtually non-existent.
• The same figures appear repeatedly in roles across legal, political and regulatory lines.
• There’s no independent appellate mechanism for regulatory failures, nor an ombudsman for structural conflict complaints.

This isn’t compliance. It’s theatre.

The GRECO angle: corruption risk in small states

Then there’s the Council of Europe’s Group of States against Corruption (GRECO).

GRECO does not wait for criminal convictions. It focuses on systemic vulnerabilities, conflict of interest policies, transparency in appointments, separation of powers.

In its latest rounds of evaluations, GRECO has been particularly concerned with:

• Public access to disciplinary procedures for judges.
• Post-employment restrictions on public officials.
• Lobbying disclosure in jurisdictions with tight institutional circles.

Gibraltar’s political and legal framework, as revealed in the Mansion case, may meet the textbook definition of such risk factors. One former minister appointing regulators while still linked to a law firm involved in litigation. A court structure with virtually no turnover at the highest levels. Legal proceedings shielded from scrutiny.

That’s not a governance model. That’s an echo chamber.

The EU’s jurisdictional headache

The European Commission has a third angle to consider: the reputational risk of association.

While Gibraltar is no longer part of the EU post-Brexit, its status as a British Overseas Territory with significant financial flows into Europe means that its practices affect EU financial markets. European citizens gambled on Mansion sites. European courts are now being asked to enforce cross-border claims linked to companies domiciled in Gibraltar.

When enforcement stalls and accountability evaporates, so does confidence in the EU’s wider integrity.

At what point does that reputational risk trigger inclusion on a watchlist? Or closer scrutiny of financial passporting, corporate registration, or AML compliance from Gibraltar-licensed firms?

The case is already being made in whispers. Perhaps it’s time for a louder conversation.

No one wants sanctions. But many want answers.

Nobody is cheering for sanctions. Greylisting hurts economies, jobs, investment and perception. But silence isn’t neutrality. It’s a choice.

Gibraltar has had multiple chances to address the issues raised across this series. Yet to date, no public inquiry has been announced. No statement from the Gambling Division. No court has reviewed the freezing order or evaluated the conflict concerns raised against senior judges.

It’s as if the operating strategy is not to solve, but to outlast.

As one international observer told Malta-Media: “Gibraltar’s model isn’t broken. It’s just stopped pretending it needs repair.”

When institutions recycle power instead of redistributing it!

In most jurisdictions, judges recuse themselves when faced with cases involving former legal partners or law firms in which they maintain long-standing professional connections. In Gibraltar, the opposite occurred.

As we revealed in Part 4 of this series, Chief Justice Anthony Dudley declined to recuse himself from proceedings involving ISOLAS LLP, despite public filings and legal opinion suggesting a reasonable observer could question impartiality.

This isn’t just a legal technicality. It cuts to the heart of due process. When the perception of neutrality disappears, confidence follows.

The fact that the previous Chief Justice, Derek Schofield, was removed following a 157-page dossier of complaints and a narrow 4:3 decision by the Privy Council in 2009 sets a precedent. If that threshold applied then, what would today’s equivalent look like?

The Judiciary, the Gambling Division, the Gibraltar Regulatory Authority and the Financial Services Commission have all declined to respond to detailed allegations contained in the Mansion litigation. Some of those allegations include mishandled data protection complaints, improperly issued WFOs and systemic tolerance of grey-market revenue flows.

Naming the enablers

The following individuals and entities have played key roles (publicly or professionally) in the governance or corporate architecture surrounding Mansion and its affiliates:

• Albert Isola: former Minister for Digital and Financial Services, long-time partner at ISOLAS LLP.
• Andrew Lyman: current Gambling Commissioner, previously of William Hill and the UK Gambling Commission.
• Peter Isola: Senior Partner at ISOLAS LLP, involved in advisory boards influencing financial services regulation.
• Michael Castiel: Consultant at Hassans, previously involved in regulatory advisory work and Mansion-related legal matters.
• James Lasry: Partner at Hassans and active participant in Gibraltar’s financial associations.
• Peter Montegriffo KC: Partner at Hassans and former Minister for Trade and Industry.
• Marcus Killick: former head of the Gibraltar Financial Services Commission, now CEO of ISOLAS LLP.
• Lawrence Quahe and PO Mak: Singapore-based legal and fiduciary consultants reportedly connected to offshore structuring linked to Mansion entities.
• Kathleen Sampoerna and Putera Sampoerna: the ultimate beneficial owners (UBOs) of Mansion, via the Putera Sampoerna Foundation and a series of offshore trusts.
• Gibraltar Financial Services Commission and Gibraltar Regulatory Authority: principal regulators in the territory.
• ISOLAS LLP and Hassans International Law Firm: legal firms whose proximity to power has raised repeated concerns.

None of these names are listed here to imply wrongdoing. But they form the network. And networks, when left unexamined, become shields.

A pattern, not a mistake

Let’s break this down. Mansion Group operated in multiple jurisdictions, including the UK, Gibraltar and Curaçao. During its operational peak, it moved substantial volumes of revenue through less-regulated payment providers, shell service companies and grey markets. When litigation arose, it shut down key entities and transitioned staff and payments to new providers, often with shared personnel, shared infrastructure or shared landlords.

And it did all of this under licence, until it no longer needed one. No fines. No post-exit audit. No critical review. Just an empty licence and a full silence.

When the EU and FATF talk about “effective supervision,” they don’t mean box-ticking. They mean acting when red flags appear. The flags here weren’t just red. They were waving from the courthouse steps.

The public doesn’t know what it doesn’t see

Even now, years after Mansion began winding down its Gibraltar operations; there has been no published review into its regulatory treatment. Unlike the UKGC or the MGA in Malta, the Gibraltar authorities have not published a single public enforcement notice regarding Mansion or its affiliate structures.

No retrospective analysis. No whistleblower protections. No statement of industry lessons learned.

And yet court documents show significant allegations of:

• Data breaches involving personal and financial information.
• Employment arrangements routed through shell firms with unclear governance.
• WFOs issued on what experts describe as legally shaky grounds.
• Conflicts of interest across regulatory and commercial domains.

All of which should, in a functioning system, trigger regulatory response or public explanation.

So who should intervene?

There are three entities best placed to ask difficult questions and back them with consequences.

1. FATF (Financial Action Task Force) Gibraltar’s record on beneficial ownership transparency, AML enforcement and high-risk sector regulation should be reassessed. Particularly around virtual assets, company service providers and legal professionals acting as intermediaries.
2. GRECO (Group of States against Corruption) With legal advisers sitting on both regulatory panels and company boards and ministers overseeing sectors in which they hold commercial interests, GRECO should conduct a review into conflict-of-interest management and institutional safeguards.
3. European Commission (DG JUST and DG FISMA) If Gibraltar wishes to maintain parity with EU standards on cross-border finance and digital commerce, the Commission should consider whether current supervision levels meet equivalence expectations.

Sanctioning or greylisting would be a strong move. But an investigation? That would be overdue.

Conclusion: reputation is a currency too

This final part of Rotten Rock isn’t about making enemies. It’s about calling time on a system that too often rewards silence, connection and choreography.

Gibraltar is home to skilled professionals and legitimate companies. But legitimacy cannot rest on secrecy. Trust must be earned with structure, scrutiny and clarity.

If Gibraltar truly wants to be a leader in digital finance and online regulation, it must welcome hard questions, not dodge them. Because in the long run, what protects a jurisdiction is not its lawyers, but its willingness to be accountable.

FAQs

Why is Gibraltar under scrutiny in this investigation?
Gibraltar is being scrutinized for systemic regulatory failures, conflicts of interest, and lack of enforcement, particularly regarding Mansion Group and its affiliates.

What is the Mansion Group, and why is it significant?
Mansion Group was a major online gambling operator linked to Gibraltar. It operated through a network of successor companies and faced serious regulatory and legal concerns.

What is regulatory capture, and how does it relate to Gibraltar?
Regulatory capture occurs when oversight bodies serve industry interests over public ones. In Gibraltar, regulators, politicians, and legal advisers often overlap, raising concerns about independence.

Who are some key figures mentioned in the report?
Notable names include Albert Isola, Andrew Lyman, Peter Isola, and Marcus Killick—individuals tied to both regulatory roles and commercial entities in Gibraltar.

What role does the Financial Action Task Force (FATF) play?
The FATF evaluates jurisdictions on anti-money laundering and beneficial ownership transparency. Gibraltar’s recent behavior could trigger renewed FATF scrutiny.

What is GRECO, and what does it monitor?
GRECO (Group of States against Corruption) assesses anti-corruption measures and institutional safeguards. The case points to weaknesses in Gibraltar’s conflict-of-interest policies.

How does the European Commission factor into this issue?
Although Gibraltar is no longer in the EU, its financial interactions with Europe make it subject to reputational and compliance concerns that the Commission may evaluate.

Has Gibraltar responded to the allegations?
Key regulatory and judicial bodies in Gibraltar have largely declined to comment or investigate the serious allegations outlined in the Mansion litigation.

Why is greylisting being considered?
Greylisting is considered when a jurisdiction shows systemic compliance failures. It signals a need for oversight rather than punishment, protecting international financial stability.

What kind of intervention is being proposed?
External investigations by FATF, GRECO, or the European Commission are proposed—not necessarily sanctions, but inquiries into Gibraltar’s governance and regulatory standards.

Legal disclaimer

This article is published by Malta-Media for informational and journalistic purposes only. The content is based on public records, legal filings, court documents and publicly available regulatory disclosures.

No statement herein should be interpreted as an allegation of unlawful, unethical or improper conduct by any individual or organisation unless such finding has been confirmed by a competent court or regulatory body.

All persons named, including but not limited to Albert Isola, Andrew Lyman, Peter Isola, Marcus Killick, Peter Montegriffo KC, James Lasry, Michael Castiel, the Gibraltar Financial Services Commission, Gibraltar Regulatory Authority, ISOLAS LLP, Hassans International Law Firm and others are presumed to have acted within the bounds of applicable laws and are entitled to the presumption of innocence and integrity.

Where commentary is offered, it is provided as fair opinion and does not purport to establish facts beyond those documented. Malta-Media welcomes responses, clarifications or corrections and will consider amendments where appropriate.