iGaming Fraud Insights—ICE Barcelona, Part 1 | "What The Fraud?" Podcast

Welcome to What The Fraud?, a podcast by Sumsub, where digital fraudsters meet their match. I'm Kris Galloway, iGaming Product Evangelist here at Sumsub, and the host for this very special episode. We're bringing you conversations straight from the floor, and just as we did at Money 20/20 in Europe and the US, we've teamed up again with our friends from C-Suite Podcast to get to the heart of the industry's biggest challenges. In this episode, I sit down with the people fighting these battles. We talk about all the ecosystems—from fast-growing markets to money laundering techniques and pressure points, to the fight against unlicensed operators. Are we ready? Let's dive in.

Olabimpe Akingba, pawaTech

KRIS GALLOWAY: A reoccurring theme that we're hearing here in Barcelona is that building a sustainable market requires more than just a license. It requires a thorough technical backbone to manage the human element of the game. That's where the technology provider comes in. With me now is Olabimpe Akingba, Head of Responsible Gaming at pawaTech, a company at the forefront of the technical infrastructure behind these global operations. Olabimpe, thank you ever so much for joining us. How are you doing? How's the event going?

OLABIMPE AKINGBA: I'm doing great, Kris. Thank you very much. Yeah, I mean, the event has been great so far. 

KRIS GALLOWAY: So let's start at the top with the first question. Considering your vast experience and expertise in responsible gaming, I'd like to ask you about the disconnect between what can actually be done to protect players and what regulators understand to be possible.

Suggested read: What is Responsible Gaming?

So technically, it's fairly straightforward to track behavioral betting patterns, such as identifying when a player is chasing losses. Yet at a regulatory level, what we tend to see being mandated are basic features like self-exclusion, timeouts, reality checks, and deposit limits. Given that, is it time to up the RG ante, or is what we have enough to protect players, in your opinion?

OLABIMPE AKINGBA: I believe the problem here, or the question we should be asking, is: do we have the right tools? Are we using these tools correctly as well? Because one risk that I've noticed, and that I hope we don't replicate here in Africa, is this proliferation of RG tools that are basically performing the same function. So it's like overlapping functions. And what I find that does for the players is it doesn't really strengthen the protection layer. What it does is confuse the players, and you see less engagement when you have this duplicity of RG tools. So I think what we should be doing is actually looking at data, and this is why I'm always an advocate for collaboration between the regulators and the operators, especially the really compliant ones. You want to find out what the data looks like. What tools do these customers really engage with? And that way, we can truly build something that is very useful for the customers.

Not just—and I speak for Africa now—a lot of the time what we do is try to copy the global market, such as the UK, Europe, and all of that. And I would very much like for Africa to develop its own standards. We should look internally at what is unique to us and try to build something around that, rather than this copy-paste model that we are seeing over time, which is actually not foolproof in these jurisdictions as well.

KRIS GALLOWAY: So you're saying that really the templates that can be used, the copy and paste model, should be used for inspiration as opposed to the default practice.

OLABIMPE AKINGBA: Exactly.

KRIS GALLOWAY: Considering how unique different regions can be. So, when it comes to unlicensed casinos targeting younger users, such as Roblox or CSGo style casinos, for example. Do you think this is a real concern for regulators right now? Or are they still kind of slipping through the regulatory net?

OLABIMPE AKINGBA: Clearly, Kris, it is slipping through the regulatory net.  But of course, this is a global concern. The problem that I see is that the regulatory bodies are actually established to oversee licensed operators. And unfortunately, there's a gap that's been created by the constant evolution of technology and all that. And of course, like you mentioned Roblox—these are not your usual everyday gambling, what we know to be gambling. So, it's more like an intersection of gaming, digital collectables, and all these things, clearly outside the regulators' oversight. So, yes, that is a huge concern. Again, this comes to collaboration. There needs to be a proactive, collaborative engagement between the gambling regulators, tech regulators, and payment regulators. And just generally the digital ecosystem. And I feel that's the way forward on that.

KRIS GALLOWAY: So if I were to use an analogy, it feels like you're saying that there are regulators that regulate the drug companies, but there's no police force to actually regulate the illegal narcotic underworld of crime.

OLABIMPE AKINGBA: Exactly. We are clearly missing out on that.

KRIS GALLOWAY: Yeah, absolutely. So certainly, in Africa, but also globally, do you see self-exclusion programs such as OASIS in Germany, for example, or such as GamStop in the UK as underused protection? Or do you see it more as a friction that can push players towards those illicit operators that we were talking about? How is it in practice, do you think?

OLABIMPE AKINGBA: There is no tool that is perfect, but I'd say I like the concept of GamStop. And I say that because it's like it's a multi-operator self-exclusion scheme, and that is great. I actually think we need more. I mean, something like that in Africa, where, at least, when a customer wants to self-exclude completely, they are blocked from every other gambling site. It's not perfect, but I feel that we would rather have that than say 'Oh no, nothing.' Again, technology evolves. It's a problem. For every problem, we should actually try to look for a solution. I feel those frameworks should evolve over time to be able to also capture the illegal market.

So, for me, I prefer that to nothing at all, or even just individual operators having their own self-exclusion tool, because you have a lot of that in Africa. What you find is some people are doing so much, especially in that regard. For example, at betPawa, we have a self-exclusion scheme that also moves into counseling. And what we've done is also to localize the counseling services to each market. So, it's not a one-size-fits-all. And that has been a very, very useful tool in terms of protection. So, I think we really do need something like that, because what you find is you find some operators doing so much, and then what happens to the customer who self-excludes on those kind of platforms, but are still able to access other gambling platforms, licensed or unlicensed?

KRIS GALLOWAY: Yeah, absolutely. It sounds like a lot of what you stand for is very much based on data-driven frameworks, communicating with regulators, and making sure that you're synchronizing all of the information, which is fantastic. So, from your position specifically as a lawyer with a great deal of experience in iGaming and beyond the responsible gaming features that we've just spoken about, do you feel regulators are missing a trick in terms of what could be changed, amended, or added to really refine and optimize player protection? Obviously, we talked about personalizing a lot of those templates that we see from abroad for the African markets. But what does that personalization look like? What do those features or procedures actually look like?

OLABIMPE AKINGBA: We need, let me say in Africa, as much as we are still developing in terms of maybe tools, what you find from the past year, is that there are a number of regulators who actually have updated regulations in terms of responsible gaming. But again, my concern is that a lot of these regulations are more reactive, rather than being proactive.

KRIS GALLOWAY: It goes back to what you were saying about data driven, responsible gambling solutions.

OLABIMPE AKINGBA: Exactly. So, it's not data-driven. It's nothing collaborative in terms of bringing in all stakeholders to really have a sit-down, discuss what the peculiarities in our industry are, and how we can go about that. So, for me at least, from what I know in Africa, I feel what we are really not doing much of—and what we really need to be doing more of—is not so much on the product layer, but in terms of education. We are not doing enough in terms of awareness campaigns.

So, for these customers, if you say, ‘Oh yeah, you are enforcing or making it compulsory for operators to have these multiple tools,’ which for me, again, like I've mentioned, just overlap, I don't really see how greatly they are helping to protect the customers.

What are we doing to educate the customers so they understand the available tools and how they can use them? And I don't mean just an operator doing it independently. I mean collaboration between the regulators, the operators, and mental health organisations.

So rather than driving all this negative media, why can't we all work collaboratively to educate? We know there is the issue of illegal gambling operators, but if we are enforcing licensed operators, what are we doing to actually make customers see that they are much better protected playing with licensed operators than with illegal ones?

So, I feel we're not doing enough in terms of education—educating the public. I also know that we need to sit and agree on proportionate tools and, finally, collaborative engagement across the ecosystem.

KRIS GALLOWAY: Absolutely. I think that in a lot of cases, the regulation feels very much like a box-ticking exercise, and you're kind of moving away from that and looking at where you can deliver value and how you can cooperate with a lot of the different regulators. One more thing that I'd like to come on to, just briefly, is if we look at the marketing within the industry, particularly, I mean, we know that a lot of it comes from the unlicensed operators in regulated markets. And we've seen some very underhand tactics, very underhand strategies as well, in terms of using deepfakes of famous people such as Mr. Beast or Khaby Lame, for example, which then lead to a casino app, which is disguised as a game on the App Store. And I think you're probably going to come back to me with a similar answer in the sense of we need to educate users and work with regulators. But how big of a problem is this in African regions, and how do you think this can be tackled?

OLABIMPE AKINGBA: It's a problem across the world. It is actually because we have a growing youth population. There's a growing part of the digital ecosystem as well, and I feel that the gambling industry is playing catch-up with. So again, I feel this is something we need to sit down and strategize on. And I feel that what I know is that operators actually seem to be able to have ideas regarding solutions or possible solutions to this, which is where the regulators come in. Because the truth is, regulators or at least across Africa. There are challenges with the data. It's the knowledge gap and all that. So, if we as operators know so much, it is important that we also proactively engage with the regulators. The regulators are also taking a stance of openness, not a defensive stance against the operators, openness, knowing that we are all partners in progress. We want the same thing, which is a safe and well-regulated environment. 

KRIS GALLOWAY: Considering we're seeing more engagement from younger generations, at least in European markets, and considering that a lot of the unregulated operators in regulated regions tend to target younger demographics with video game-style ecosystems, with social layers, with next-generation games, do you think that regulated operators are doing enough in terms of innovation to almost keep up with that? Or do you think there's scope for improvement there in a responsible and safe manner?

OLABIMPE AKINGBA: The licensed operators are not the problem, actually, it's the unlicensed operators. There is clearly no oversight of them. They can do as much as they want. Again, it takes me back to the gap in communicating with customers, especially with the young demographic. I've done a number of advocacies in Africa, specifically in Nigeria, especially with these NGOs. And why I seem to be saying that we need to be out there. Literally educating people. So now this is underage because it was a school-like high school advocacy program. And they're talking to this young demographic to say, 'What you should focus on right now is your studies.' You have no business gambling. It is illegal. Actually, it is against the law for you to partake in gambling and all of that. And I had one of them ask me and, Kris, it was quite shocking.

KRIS GALLOWAY: What did they ask?

OLABIMPE AKINGBA: I had one of them ask me. Okay, so you keep saying we should not gamble like what I see is I'm from this side of life, where my family is not doing great. We are poor and all of that. I know if I do this, I will make money. Would you rather I do this or that I'm a fraudster?

KRIS GALLOWAY: That's so sad.

OLABIMPE AKINGBA: That's really sad. You can imagine the extreme option this young chap is given to speak on this side. I'm actually not in court committing a crime. This is about me. It's my money. I actually work anyway to earn money. These are real-life arguments. We can all sit down behind the platform and say we are developing tools. That young guy knows nothing about it. He is not interested in that.

KRIS GALLOWAY: And this is someone who's intelligent enough to at least ask this question in this case, imagine people who are looking at it from a similar perspective, but don't have that intelligence, then being targeted by those nefarious adverts that you're talking about.

OLABIMPE AKINGBA: So you see the work we have at hand.

KRIS GALLOWAY: Absolutely. Olabimpe, it's been an absolute pleasure. Thank you ever so much, but it's been a pleasure having you on.

OLABIMPE AKINGBA: Thank you again, Kris. Thank you for having me.

Ludovico Calvi, United Lotteries for Integrity in Sports

KRIS GALLOWAY: While regulation provides the framework, the actual line of defense against unlicensed activity often comes down to enforcement. But when you zoom in on sports betting, the stakes change. Fraud here isn't just about a single bad actor stealing from a platform. It's about organized networks and suspicious patterns that really threaten the integrity of the game itself. In this arena, monitoring and global collaboration aren't just helpful; they are the whole game. I'm joined by Ludovico Calvi, who is the Honorary President at the United Lotteries for Integrity in Sports. Ludovico, thank you for being here.

LUDOVICO CALVI: Thank you for having me, Kris.

KRIS GALLOWAY: So let's jump in. You've spent decades working on sports betting regulation across multiple markets, and you've seen fraud evolve from low-tech document tricks, from fax machines and laminating documents to today's coordinated AI-enabled networks. How do you think AI is going to further fuel fraud over the coming years, and what should we really be looking out for?

Suggested read: AML Casino Compliance and Responsible Gambling Standards: Global Guide 2025

LUDOVICO CALVI: Well, AI will industrialize fraud. There's no question about that.

KRIS GALLOWAY: It already is.

LUDOVICO CALVI: It already is and is becoming even more and more. And operators have not really detected the real challenges here. We have three areas, big areas.

First is the process of onboarding a customer. And I mean, fake identities, synthetic identities in general, having a network of opportunities, because these organizations basically are organized in a network.

The other point is the camouflage behavior. So, you cannot detect, for example, a compulsive behavior, let's say, because the AI will actually mimic it, mimicking recreational behavior rather than pure fraud. And that would obviously be on a scale of several hundred accounts. And it would be difficult not only for operators but also for all the compliance teams to detect that type of fraud. So, this is what I mean by industrialized.

And then the scale, Kris, the pure scale we're talking about, strategies across jurisdictions, making sure that fraud will take place at a global scale. And that's why if you don't have a global network of detection, it is very difficult.

KRIS GALLOWAY: Absolutely. Whereas in the past, we've had to tackle advanced bots that try to mimic human behavior. Now essentially, they're building themselves, and they're attacking themselves.

LUDOVICO CALVI: We talk about the Agentic AI and GenAI, of course. So, they're learning. They're learning from the success rate they are getting. And if they actually are looking at good success rates, they will continue to build on that.

KRIS GALLOWAY: Yes, it becomes very self-learning in that respect. And they'll double down on what works and trash what doesn't. So, as the Honorary President of the Sports Integrity Association, you also work with the FBI, with Interpol, with Europol, for example. And you do this to detect suspicious betting patterns, right? What's the collaboration look like, and what do those patterns look like as well, while we're here?

LUDOVICO CALVI: Well, what trading floors ULIS has something like 50+ members. So, 50 trading floors worldwide, from Hong Kong to South America to Canada, are detecting suspicious betting patterns simultaneously. We would, of course, internally exchange the type of information we are getting, because often the way it works is that the money is coming from one continent, let's say Asia. The event is taking place somewhere in South America, and the bet may be placed in Europe. So, you need to have a network of information. So key data is key. But above all, exchanging key data is key. So, we would have an escalation process for which once we detect that there is a coordinated red light worldwide, then we will escalate towards not only law enforcement agencies but also the world of sports: the leagues, FIFA, UEFA, all the organizations, sports organizations we work with. And of course, there will be a process. Let's not forget you have sports law and criminal law. And this is an issue when we talk about taking these guys to court, because you could have an athlete who is suspended, but it's not a crime in the jurisdictions he’s working, or the other way around.

Suggested read: How Money Is Laundered Through Football

Someone who's been arrested. But for the sports law, which takes, of course, longer to actually take the athlete to court, will not even be suspended. So, what the law enforcement agencies do is basically trying to cross the pattern, when the patterns cross borders, and when criminal organizations' indicators are there, and we can see there are activities of money laundering, such as, for example, by criminals to acquire a second or third division football team just with the unique objective to launder money. Well, that's when the law enforcement agencies come and play a role. In particular, Interpol has got a phenomenal system to exchange information because of GDPR and privacy laws. We have encrypted all the information exchanged. So, whatever we provide to them is obviously only accessible to the prosecutors and not anyone else. So, this is making, of course, integrity much more preventive and less reactive. And this is where we want to go. We really want to be in a preventive mode, and not in a reactive mode. It's a question of really collective action and collective responsibility, but not when it's too late, Kris.

KRIS GALLOWAY: Absolutely, collective action on quite literally a global scale.

LUDOVICO CALVI: On a global scale. I remember when I was involved with the process of legalization of sports wagering in the US, and US stakeholders would say, Well, we need to have our integrity platform, but you cannot have a US-wide only integrity system because the phenomenon is global, and you're not going to address that, of course.

KRIS GALLOWAY: Just because of the threat of cross-border fraud. Absolutely. So, another pressure point is market incentives. We've seen a rise in iGaming taxes across several regions, not just a few. Do you feel there's a risk of a cobra effect, where higher taxes unintentionally push more players and activity towards unlicensed operators? And what were some of the warning signs that you'd look out for?

LUDOVICO CALVI: Well, one of the missions of (ULIS) United Lotteries for integrity in Sports and before that what was called GLMS, Global Lottery Monitoring System, was just to really convince regulators that we need to keep sustainable market levels. I mean, the product lifecycle, the lifecycle of sports betting in general needs to repay itself. You cannot have an unsustainable and non-economically viable market environment because inevitably operators will get out or will be forced to get out because customers will obviously be getting and buying in illegal betting services somewhere else, and then it will be a lose-lose. On the other hand, we always said it's extremely important to legalize sports betting everywhere, and I've been actually at the forefront in Canada, the US, Brazil, Italy, and Europe to really convince politicians and stakeholders. Not easy, believe me.

KRIS GALLOWAY: Of course.

LUDOVICO CALVI: They don't see gaming as the health system, and, therefore, it's not a priority to make sure that the legalization process is really generating revenues for the community. At the same time is obviously safeguarding consumer protection, which is key.

KRIS GALLOWAY: Of course. I mean, iGaming is an industry that's so layered. Even from people who are in the industry. There are things that we don't see. So, from a politician's perspective, I imagine that you peel the onion back a little bit.

LUDOVICO CALVI: And when I was talking to governors in the US, the objective was, Okay, we have a budget. The budget is that we're going to make so and so much money from sports wagering.' And I was saying, no, you are not, because your tax levels are absolutely crazy out of the market, and you're going to only make 2% of the overall market emerge because 98% will be actually still underwater. So, this was the type of conversation to prove with evidence that in other markets, there have been best practices, things have actually been going in the wrong direction.

KRIS GALLOWAY: Absolutely. Talking about the gap between regulators and between operators, when we look at what's technically possible today, regulations sometimes feel like they can be a step behind. Do you feel as though regulators have a strong enough grasp of what can actually be achieved through things like betting analysis or transaction monitoring?

LUDOVICO CALVI: Well technology moves faster and evolves faster than any regulatory framework. That's clear.

KRIS GALLOWAY: And especially with AI.

LUDOVICO CALVI: Especially with AI. And there is a challenge there to keep up with what's happening. So, you're always following. I had a panel yesterday with the UK, French, and Norwegian regulators talking about being a little bit more innovative in a phenomenally, highly technical market environment, dominated today by AI but will be dominated by AI very soon. So many regulators still have, Kris, provisions based on static information, static reporting rules, threshold-based patterns, and siloed operators organizing in a way that they don't talk to each other. So, this is something that needs to change.

KRIS GALLOWAY: 100%

LUDOVICO CALVI: Because you need to be more on the probabilistic network. Even looking at a network as an entity rather than individuals. Because if you look at individuals, you will not get the evidence that you're looking for. And again, going back to collective action, collective responsibility. This is part of a licensed ecosystem, a regulated ecosystem to fight the illegal market. And you can fight it because you really make decisions together. So, operators and regulators need to sit at the table and talk about the issues we have, because they are both on the same side of the table. Challenged by the illegal market.

KRIS GALLOWAY: Ludovico, I could sit here and talk with you all day. It's an absolute pleasure, but unfortunately, we're out of time. Thank you so much for attending.

LUDOVICO CALVI: You’re most welcome. Thank you for having me. Thank you.

KRIS GALLOWAY: Thank you ever so much.

Sarah Gardner, UK Gambling Commission

KRIS GALLOWAY: A big talking point this week is the balance between innovation and oversight. Operators can build the most advanced controls in the world, but regulation is what defines what good actually looks like. And that gets especially sensitive when we look at protected groups, legacy products like lotteries, and the persistent challenge of unlicensed sites. I'm joined by Sarah Gardner, Deputy Chief Executive Officer at the UK Gambling Commission. Sarah, it's great to have you here.

SARAH GARDNER: Lovely to be here. Thank you.

KRIS GALLOWAY: So you participated on a panel here at ICE alongside other European regulators discussing whether lotteries should sit apart from other forms of gambling, like online casinos and bingo. So, to kick start the conversation, what is it about lotteries that genuinely sets them apart? At least from a from a regulatory point of view.

SARAH GARDNER: Okay. So, I think lotteries are distinct in three respects really: in their structure, their risk profile, and their purpose. In countries like my own in Great Britain, they have their own legislative status. So, they're defined in legislation, which is helpful. They tend to be lower-frequency, generally less risky products, although we do have to be a bit careful with that. And an important thing about lotteries is they have a clear purpose, and that's normally to raise funds for good causes, which of course is really important.

KRIS GALLOWAY: Yeah. I think the frequency point is something that's often overlooked. People don't take that into consideration when comparing the two to each other.

SARAH GARDNER: Yeah, it's particularly interesting. I mean, on the panel yesterday, I was speaking about the comparison that's often drawn between online instant win games in lotteries and online slots. And lots of people say, 'Oh, they're just the same. You should regulate them in the same way.' And I think as a regulator, that could be quite dangerous because actually you need to look at risk on a case-by-case basis. So, if I take the example of those games in the UK on the UK National Lottery, typically, an online instant-win game would have a speed of play of about 115 seconds. Whereas our rule on online slots is five seconds between game cycles, which is a whole different thing from a risk perspective.

KRIS GALLOWAY: And even though you have different forms of lotteries within casinos, I imagine they roll and rotate every few minutes or every few hours, as opposed to every Tuesday and every Thursday, for example.

SARAH GARDNER: Absolutely. You don't get the high frequency.

KRIS GALLOWAY: Absolutely. So, the Gambling Commission reports that 59% of young people in the UK, which is defined as those aged between 16 and 18, if I'm not mistaken, have engaged in some form of gambling, and looking at this, I imagine this must be one of those questions you get all the time. Is there a fear or concern that national lotteries can act as a gateway into more concerning forms of gambling?

SARAH GARDNER: All of our regulation has really stringent requirements in terms of age verification and operators taking proper steps to make sure that they're not serving people who are underage. I think in terms of the research you quoted, it's quite important to understand what that research was asking. So quite often, the young people, when they were talking to us about experiencing gambling, weren't necessarily talking about having spent any money gambling, for example. So, it would be things like helping their parents pick a horse in the Grand National.

KRIS GALLOWAY: Right.

SARAH GARDNER: Or helping someone pick some numbers on a lottery draw or something rather than directly participating. 

KRIS GALLOWAY: That’s interesting.

SARAH GARDNER: When you actually come to them, spending money. So, we had about I think the figure was 6% of them said they had spent money on any age-restricted gambling product. In terms of National Lottery, that was about 1% who had engaged in both draw-based games or instant products like scratch cards or something.

The other important thing is that the age limit in the UK was raised a few years ago, from 16 to 18 for lotteries. The rate of play for 16 and 17-year-olds, was already quite low even before that change, but obviously that change has effectively reduced it to zero. So, as I say, while we wouldn't be complacent, there are lots of controls in this area, I think, to make sure that the lottery is safe for everyone to play. 

KRIS GALLOWAY: And it seems as though from what you're saying, the context is much broader than people tend to realize as well. When we take into consideration the young people who do take to gambling sites as well as the strategic targeting of younger players using AI from the more illicit operators, how do you think we can protect young people from those threats?

SARAH GARDNER: I think, and I'll answer this both as a parent and as a regulator, if you like. So, as a parent, I'm a strong believer that gambling is one of those topics that people ought to be talking to their kids about and helping them stay safe, and helping them to understand what safe behavior in gambling is and what might be more risky.

KRIS GALLOWAY: And it's not something that people really think about, though, is it? There are so many of those sensitive conversations you have to have. But gambling never really comes up in that context.

SARAH GARDNER: Yes, absolutely. And I think, from a societal perspective, there's something to think about there. From a regulatory perspective, our focus has been on making sure that one of our core licensing objectives is to protect children and vulnerable people from harms associated with gambling. So, focus on children is really at the heart of our regulation, which is why anyone who's licensed with us is subject to really strict requirements about making sure that they're not serving underage people and all the rest of it. So, it's both education for young people, I think, to make sure they understand. But also making sure, frankly that the door's closed and they can't access products that they shouldn't be able to access.

KRIS GALLOWAY: Yeah, absolutely. I mean, I completely agree in regard to education. I think if we, I mean, at least for me, having grown up in the UK, when we look at something like the think campaign for drunk driving, for example, do you think there should be something similar to that focused on gambling, or would that be a little bit too much?

SARAH GARDNER: I think there is a role for, I mean, more generally, not just for kids, but making sure that people understand gambling. And that's something again we're very focused on in our regulation, which is making sure that consumers have the tools to understand what the gambling you're engaging in is, what the risks are, and what the opportunities are.

KRIS GALLOWAY: Raising awareness in general.

SARAH GARDNER: Raising awareness in general to help them to help themselves.

KRIS GALLOWAY: Absolutely. So, after all, we're here to talk about fraud. The UK is leading the way in blocking illicit operators. But we're still able to visit a number of unlicensed sites from UK territories: Create an account, deposit, and play. What do you think we can really do to crack down on these sites?

SARAH GARDNER: Our strategy has been to stop illegal gambling from operating at scale in Great Britain. And I think what that recognizes is you won't ever obliterate it. Because it's not that kind of thing.

KRIS GALLOWAY: It's more of an arms race than anything else, isn’t it?

SARAH GARDNER: Absolutely. So, our focus has been on stopping that from operating at scale. And we've been doing that. And we're pleased to get some new powers in this space. But even ahead of that, one of the really powerful things we've done is to build partnerships with other people and other organizations who have a role to play in this. So, people like payment providers, platforms, domain registrars, all of that kind of stuff, and so between us we can find a way through, and also, it's another area where I think there's a role for raising awareness about what's safe and what isn't.

KRIS GALLOWAY: Yeah, absolutely. I think alignment with regulators and raising awareness is something that keeps coming up over and over again. So, looking ahead to 2026, what's the biggest shift you expect in iGaming fraud and compliance? And what should the industry be doing now to prepare for that?

SARAH GARDNER: So, one of the things we're thinking about quite a lot is what I would call the industrialization of illegal gambling, enabled by things like AI, which obviously allows operators who are inclined to operate at scale.

AI in gambling is a double-edged thing that can be really powerful in commercial terms. We’d also certainly like to see, in the licensed market, operators using AI to support players, identify risks at an earlier stage in their gambling journey, and intervene.

KRIS GALLOWAY: Yeah. No, that makes sense. That's all my questions. Thank you ever so much for coming on to ‘What The Fraud?’.

SARAH GARDNER: Thank you for having me. It's been a pleasure. Thank you.