Interview
8 min read
Unregulated gambling continues to compete with licensed operators across many markets, often with fewer restrictions around pricing, products and promotion. For regulators and operators, the challenge is not only creating a compliant marketplace, but one that players actually choose.
As President of Gaming Compliance International, Ismail Vali focuses on how regulated gambling marketplaces can compete effectively while protecting consumers. In this interview, he explores why players continue to choose unregulated platforms, how regulation can balance protection with competitiveness, and why advertising, enforcement and player adoption all matter when measuring whether a regulated marketplace is truly working.
Unregulated gambling continues to compete with licensed operators in many markets. Why do you think players still choose unregulated platforms even when regulated alternatives are available?
Players choose on price, product and promotion. On all three, the unregulated sector often presents the stronger offer.
Unregulated operators carry no tax, licence fees or compliance costs, and apply none of the controls required of licensed operators. On price, that funds better odds and larger bonuses. On product, it allows faster sign-up, crypto payments and games the regulated sector cannot offer. On promotion, it places unregulated brands on unregulated streams, social media, influencer channels and messaging groups, where licensed brands cannot appear.
Customers see an ocean without distinction, not regulated or unregulated. Consumers do not experience the marketplace through regulatory labels, and many do not know the site they use is unregulated. A professional-looking site that pays out quickly carries no visible sign of its regulated status.
Most players are not choosing crime. They are choosing the better offer, and crime is supplying it. The question for every jurisdiction is why its regulated marketplace leaves that choice open.
What makes a regulated gambling marketplace genuinely successful, not only from a compliance perspective, but also in terms of competitiveness and player adoption?
A regulated marketplace is successful when the regulated sector wins the consumer, not only the audit.
Many jurisdictions measure licences issued, fines collected and tax received. None of these shows how much consumer spend flows through the regulated channel. GCI’s figures put the 2025 US online gambling marketplace at around $125 billion, of which approximately $28 billion was regulated. A sector can be fully compliant and remain a minority in its own marketplace.
Success rests on policy, process and practice. Policy defines the marketplace and who may operate in it, with a tax and product framework that allows licensed operators to compete on price, product and promotion. Process gives the regulator visibility of the whole marketplace: regulated, unregulated and unacknowledged. Practice is the consistent enforcement of that policy against everything operating outside it.
GCI assesses this through Marketplace Outcomes: consumer protection, integrity, tax contribution, transparency, responsible participation and reduced criminal exploitation. Player adoption is the evidence that compliance is working. A marketplace in which every licensed operator follows every rule while most players gamble elsewhere is not a regulated marketplace. It is a regulated minority.
Regulation is designed to protect players, but overly restrictive frameworks can sometimes make licensed operators less competitive. How can regulators find the right balance between protection and creating a viable marketplace?
The balance is found by regulating the marketplace, not only the regulated operators.
Most rules are designed around what licensed operators should stop doing. The equally important question is how a rule changes the price, product and promotion of the regulated offer, and where the player goes as a result. Germany’s spin-delay requirement was designed to protect players. Many experienced the regulated product as unfair and moved to the black marketplace, where no protection applies.
A rule that protects players in policy but pushes them offshore in practice is not protection. It is displacement.
Each jurisdiction is entitled to determine its own marketplace, whether restrictive or liberal; that decision belongs to lawmakers and voters. Once made, it requires process and practice: monitoring, policing, enforcing and optimising. Each rule should be tested against the whole marketplace before introduction, measured afterwards and adjusted where necessary. Balance is not a fixed setting. It is a measurement taken continuously.
When regulated operators face stricter rules around advertising, bonuses, product features, or payments than unregulated competitors, how can they continue to compete effectively for players?
Regulated operators cannot compete by matching the unregulated sector on its terms. A licensed operator will not out-price or out-bonus a competitor that pays no tax and ignores every rule.
On price, the regulated offer competes on value rather than headline generosity: fair terms, certainty of payout and speed of payment. A winning player on a licensed site is paid. On an unlicensed site, payment is not guaranteed.
On product, games are largely commoditised. The experience around them, including service, data security, personalisation within the rules and a genuine route to complaint and redress, is what wins and retains players.
On promotion, the regulated sector’s advantage is trust: a brand the player recognises and expects to exist next year.
Product alone will not close the gap. Operators also compete by raising the cost of unregulated operation: working with regulators, payment providers and advertising partners, and supplying evidence of where customers are being lost. Licensed operators are the black marketplace’s best-placed witnesses.
How important is advertising in this equation? Can restrictions on how licensed operators marketplace themselves unintentionally make it harder for players to distinguish regulated brands from unregulated ones?
Promotion is central. In a marketplace consumers cannot judge perfectly, advertising is how they assess legitimacy.
Restricting licensed advertising does not reduce the volume of gambling advertising consumers see. It changes who supplies it. When regulated brands withdraw, unregulated operators occupy the space on unregulated streams, social media and influencer channels. GCI’s research found that 84% of unregulated streaming is advertised upon by unregulated gambling, and that during the World Cup, 95% of 174 billion unregulated stream views carried unregulated gambling advertising.
Unregulated operators replicate the look and language of licensed brands, and a licence logo in a website footer means little to consumers. If the only gambling brand a young fan sees during a match is unlicensed, that brand becomes the norm.
Advertising policy should regulate the content and responsibility of promotion, not the visibility of regulated brands, and enforcement practice should apply equally to unregulated advertising and the platforms carrying it. Otherwise, advertising rules protect consumers from the regulated marketplace and leave them exposed to the unregulated one.
Enforcement is often discussed as one of the biggest challenges in tackling unregulated gambling. Where do you think current enforcement approaches are falling short, and what needs to change?
Current enforcement concentrates on the target it can least often reach: the unregulated operator.
The principals behind unregulated online gambling sit outside the jurisdiction, behind offshore licences and layered corporate structures, and replace a blocked domain faster than a regulator can issue a notice. Site-blocking alone does not change the marketplace.
In many jurisdictions the gap is in process and practice, not policy. The laws exist. What is missing is a practice aimed at the ecosystem that sits inside the jurisdiction: payment providers, advertising networks, affiliates, platforms, app stores, streaming hosts and, in some cases, software suppliers whose technology is used through third parties. These businesses respond in days, not years. Enforcement that targets the ecosystem changes the unregulated operator’s economics. Enforcement that targets only the operator brand changes its web address alone.
The process behind that practice requires continuous intelligence on the whole marketplace, case-ready evidence that stands up in court, and coordination with the financial, media and telecoms regulators that hold powers gambling regulators lack. Success should be measured by how much of the marketplace returns to the regulated sector, not by the number of domains blocked.
The gambling industry operates across very different regulatory frameworks around the world. Are there lessons from particular markets that you think other jurisdictions should be paying closer attention to?
Several marketplaces offer lessons, and the most useful are often cautionary.
The longest-standing is Las Vegas. Organised crime dominated it for decades. Regulation, licensing and a decision to own and control the marketplace changed that and brought in mainstream investment. Regulation, properly applied, makes a gambling marketplace investable.
The more recent lessons fall across policy, process and practice:
The common thread is to define the marketplace before licensing it, measure all of it and enforce against everything outside it. Jurisdictions that stop at licensing end up regulating a minority of their own marketplace.
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