Strategic focus 2: Enhancing our core operational functions
The gambling industry continues to evolve and develop at pace. As the regulator of this industry, we must ensure that our regulation continues to adapt and evolve so we continue to regulate effectively in the public interest.
Tackling illegal gambling
We will: Continue to strengthen our high-impact disruption tactics to deter unlicensed operators from targeting GB consumers at scale. At the same time, we will enhance our investigative and strategic capabilities through investment, specialist knowledge-building, and further use of technology. We will also challenge the regulated sector, including B2B providers, to uphold a zero-tolerance approach to illegal market activity in the supply chain. Achieving this will require strong partnerships with key regulators, online third parties, and law enforcement agencies across relevant jurisdictions. We have developed strong insights on which disruption activities work best and this, in combination with new powers and further technological capabilities, will allow the Gambling Commission to diversify its approach to disrupting the illegal market.
Why: This aligns with our statutory duties to keep crime out of gambling and protect the young and vulnerable from harm. While efforts to disrupt unlicensed operators offering products within the GB market at scale during the previous business plan period have been effective, sustained action is needed to maintain and build on this progress, reinforcing wider confidence in the Commission.
As a result: Unlicensed operators will face greater difficulty accessing the GB market at scale and, where they do, will encounter an increased risk of prompt and targeted disruption activity by the Commission, along with a growing number of enforcement referrals to third-party partner agencies and regulators both nationally and internationally. Licensed operators, including B2B operators and white-label partners, must also continue to play their part and will come under heightened scrutiny, including regulatory enforcement action in cases of identified non-compliance or poor practices related to activities linked to illegal market supply chains.
And the impact for our stakeholders will be: A better understanding of the unlicensed gambling market and consumer behaviour in relation to it and a stronger evidence base to inform how disruption activity can be strengthened.
Implement new operational systems and processes
We will: Continue to implement new operational systems, including a Case Management System, to streamline and optimise the process of managing cases through operational teams that manage the licensee lifecycle – Licensing, Compliance, Enforcement, Intelligence, Forensics and Anti-Money Laundering (AML).
Why: This supports our strategic commitment to evolve our licensing, compliance and enforcement work, including improving our core processes and technology systems.
As a result: Internally, our operational teams will be better equipped to make decisions, collaborate and handle casework more efficiently.
And the impact for our stakeholders will be: Once new systems are fully embedded licensees and third parties will receive an enhanced experience, with improvement to response times, consistency of case management and quality of service.
Developing relationships with key law enforcement partners
We will: Implement changes to intelligence processes to improve intelligence flow, intelligence sharing opportunities and enrich the Commission’s overall intelligence picture.
We will develop and coordinate our established networks and relationships with key law enforcement teams and regulators to better identify and assess emerging areas of risk and harm impacting the sector. We will also share intelligence insights both internally and externally, with a focus on national and regional-level activity.
Why: The Commission has established strong networks with law enforcement partners and key regulators, collaborating across various areas to prevent money laundering, terrorist financing, fraud, sports betting integrity issues, and restrict access to illegal gambling in both remote and non-remote (online and land-based) sectors operating primarily within Great Britain. The acquisition of a new intelligence platform, along with the soon-to-be-developed risk-based approach to intelligence (including the introduction of MORILE), presents opportunities to further enhance these external networks. This will improve intelligence flows through greater automation, data sharing, insights, proactive workflows, and reporting opportunities—ultimately strengthening collaborative efforts to prevent gambling from being linked to criminal activity, particularly organised crime groups (OCGs), money laundering, fraud, and terrorist financing, while reducing access to illegal gambling.
As a result: The volume of intelligence sharing between the Commission and law enforcement partners will increase, and strengthening the intelligence framework will support the development of both proactive and reactive intelligence practices based on risk. This will enhance our approach to the targeted deployment of operational resources, leading to more focused enforcement interventions. Ultimately, this will provide better insights into illegal activity impacting the market. This information will strengthen our understanding of emerging threats and will be shared with the industry to ensure it remains vigilant to evolving risks within the market.
And the impact for our stakeholders will be: Improved intelligence sharing and proactive enforcement will enhance market integrity and risk management, helping stakeholders address emerging threats. Stronger collaboration with law enforcement will streamline actions against illegal gambling, boosting public confidence in the sector. The improved framework will enable timely responses to evolving risks.
Changes to statement of principles on financial penalties
We will: Implement any approved changes arising from our published consultation on changes to the statement of principles on financial penalties.
Why: The outcome of the consultation will enhance the clarity and transparency in how we calculate financial penalties resulting from enforcement activity.
As a result: If the proposed changes are adopted; the Commission’s financial penalty calculation process will be streamlined in the majority of cases; leading to a reduction in delays associated with this aspect of enforcement casework.
And the impact for our stakeholders will be: If adopted, the newly defined structure of the financial penalty calculation process will enhance confidence by making decisions more predictable, transparent, and accountable. Stakeholders will have a clearer understanding of how penalties are determined, engage more effectively with the Commission, and be encouraged to achieve compliance at the earliest opportunity to avoid or mitigate financial penalties imposed by the Commission.
Compliance and assurance approach
We will: Continue to develop and implement a data driven approach that enables more effective targeting of non-compliance. Using this risk data and trends from wider compliance activities will allow us to identify areas for thematic, targeted assurance work. Alongside assurance statements we will pilot the gathering of additional sources of assurances from licensees, such as self-assessment and engagement with internal audit.
Why: To ensure we are taking a risk-based and proportionate approach to gaining assurance of industry compliance and utilising compliance resource in the most effective way.
As a result: Implementing a more targeted approach to compliance activity and potentially gaining more assurance from licensees will lead to faster and more effective identification of non-compliance.
And the impact for our stakeholders will be: Having assurance that the regulator is focussing its resources and attention on those areas that have the greatest impact upon the statutory licensing objectives.
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Strategic focus 3: Setting clear, evidence-based requirements for licensees
Last updated: 7 April 2025
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