KPMG Gibraltar eSummit 2026 - Sue Young speech
12 June 2026
This speech was delivered by executive director for operations Sue Young at the KPMG Gibraltar eSummit on on 11 June 2026.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Good morning everyone, thank you everyone for that warm welcome. I’m Sue Young and I’m pleased to be with you today here in Gibraltar, giving my first speech representing the Gambling Commission back in Great Britain. I started at the Commission as Executive Director of Operations just under 3 months ago in March. And even in that time there has been plenty going on in the gambling sector. So today I want to spend a little time giving you an insight into who I am and what my background is. And in doing so I will then give you my view on where we at the Commission are on a number of fronts.
Alongside regulating a strong compliant licenced market, tackling illegal gambling is of course a key focus for my teams. So I will give you my overview of the challenges it presents and also how we approach tackling the illegal market. And that includes how we need to avoid being distracted by some of the commentary out there and focus on how we can keep frustrating illegal operators from trading at scale in Great Britain (GB). The fight against illegal gambling is one we all need to be part of as well. So I want to make the case today for everyone with an interest in combating the illegal market being part of that effort and the value we all get from working together.
Before I finish, I will cover how we want to support the licenced market to innovate as well and touch on a few ways we are looking to support that in the year ahead.
But first, you might be wondering who I am. Well before I joined the Commission, I was at His Majesty's Revenue and Customs (HMRC) working as Director of Debt Management. And before I move on, as an aside: having dealt with affordability assessments at HMRC, I can assure you Financial Risk Assessments are certainly not affordability checks. As I am sure everyone in this room is aware, the Commission’s Board did meet in May and did consider next steps on Financial Risk Assessments (FRA). It was presented with an extensive evidence base but has not yet fully completed its assessment of that evidence. We know how important this is and I think that’s why the Board are making sure they take the time to judge this from all sides. Whilst I’m happy to take questions on this later, there really isn’t anything further to say today but of course, when there is, we will update everyone with the details.
Before HMRC, I was at the Home Office. One of my roles there was as regional director in Border Force – a role that like this one, brought me out to Gibraltar – albeit on a very different ship than this. Throughout my career, I’ve been looking to deliver operational impact for the public bodies I’ve worked for. And as Executive Director for Operations at the Gambling Commission in GB, I have been really pleased to get stuck in with a group of new colleagues who are all as committed to strengthening our work and outcomes as I am. It is a great privilege to be heading up our Licensing, Compliance, Intelligence and Enforcement teams and of course our Illegal Gambling team as well.
The opportunity to tackle the illegal market was, I have to say, one of the things that attracted me to the role. My career to date has given me opportunities to understand where criminals might be looking to make money. And when I look at the illegal gambling market, I see parallels with other criminal markets.
Ultimately, criminals are looking to make money and in gambling, they see a market with potential. They can relatively quickly set up - online in particular – avoid all the agro of obtaining and complying with a licence and start looking to bring in the cash. Yes, there are other types of agro, constantly having to navigate blocks and barriers put up, maybe concealing payments and other tactics. But like other markets, technology enables without judgment. And as we have seen in the fraud market, we have moved through seeing solely small organisations to seeing the development of larger, more sophisticated operations looking to operate at scale.
I don’t say any of this to be pessimistic though. Being clear eyed on the challenges is the first step to dealing with them. To that end, I have been really impressed with the work going on in our Research and Statistics team on getting to grips with the trends and make up of the illegal market and who gambles with it. If you haven’t read through last year’s report I’d encourage you to do so.
Tackling illegal gambling is challenging then. But that doesn’t mean taking action is pointless either. Already I have seen too many reports talking about sensational numbers of illegal sites across the internet and whilst they may be true – it’s impossible to say without seeing their workings – such figures and reporting miss the point. Illegal gambling has existed as long as there has been legal, licenced gambling. It always will exist and there is nothing I or any of you can do to fully stamp it out. What we are focussed on, is doing everything in our power to stop illegal operators working at scale in GB. Stopping them building a firm footprint in our jurisdiction.
But how do we do that? And can we have an impact in what promises to be an even more challenging climate over the next few years?
Another great thing about the job I have is coming in and seeing the progress we’ve already made. And the extra money - £26 million over three years – committed by the UK Government is also very significant. Now of course, many if not all of you will want to know exactly what we intend to spend that money on – this year we receive an extra £7 million. But let me say now – neither I today, or any of my colleagues at the Commission will ever tell you exactly how we’re making use of the new resources we’ve been allocated. Not publicly – to do so would be to help the criminals we are trying to stop. But what I will do is speak more about how we approach this important work and how that approach is going to evolve as we go forwards.
And this takes me back to why I think some of the commentary about the vast numbers of sites or criminal enterprises is to some extent a distraction. I’m not saying total volume isn’t important, it is, but we need to use the resources we have in a smart and efficient way, to make the most impact. If we can frustrate, shut down or cut off the payment flows to an illegal operator that is scaling up or has already scaled up its operation we protect more consumers than if we equally divide our resources against every illegal operator we come across. By cutting down those illegal operators who are cutting through, we also have a much bigger impact on protecting the licenced market as well.
So this is our approach. We have already invested in how we can identify and monitor sites of interest, we have built the capacity to build evidence through test purchasing and other tactics. And we continue to build and invest in the partnerships with others who can further disrupt and cut down illegal operators – including other regulators like Andrew and the team here and law enforcement, but others too. Payment providers, internet search providers, domain hosting companies, financial institutions and many more, we want to work with them all. We will target the biggest threats and through a combination of upstream interventions and use of our formal powers we will continue to frustrate them, push up the cost of targeting GB consumers and find ways to take the fight to them, making life uncomfortable for them wherever in the world they are.
And when it comes to describing how we use our formal powers that I mentioned, the same applies. I know, it can be frustrating if you provide us intelligence on a bad actor or a criminal enterprise and then don’t hear much from us. We do get it. But in the same way I won’t describe blow by blow what we will be spending the additional funding on, nor can we risk live investigations in order to share updates with you. We appreciate every piece of intel you and others provide us – big or small. We can’t have the impact we do without it. So please don’t feel deflated and please do keep sending it in. And again, where we bring formal cases – the level of resources involved mean we aren’t going to sweep across the whole market. Where we commit this resource it will be targeted on pulling bad actors out at the root.
And this is broadly the approach we have already been following and developing for the last couple of years. And it has delivered tangible results. Last Financial Year the Commission, working with partners delivered:
741 Cease and Desists issued to advertisers and operators
397,527 URLs reported to various search engines and seen 266,667 URLs removed within the Financial Year
1068 websites referred to the search engines for delisting
1134 websites disrupted so that they have either been taken down or geo-blocked.
And the research the Commission continues to publish since last Autumn also gives some perspective on this. An update was published in April which I would recommend reading but to cover the key points that we are interested in today, the update brought the trend data on the illegal market almost up to date. Extending what we have published from July last year through to February this year. We of course need to be open about the assumptions and margins for error associated with any estimate of illegal gambling, but the new overall trendline does not appear to show a consistent or sustained growth in consumer engagement over the now, 21 months of data. The team have explored the effects of seasonality and changes in VPN use as well and neither suggest persistent growth.
It’s always important not to over rely on data from a single source to tell the whole story on a topic as complex as illegal gambling. As a result we will continue to work on improvements to our methodology and – alongside gaining more insight from our own research – will continue to seek input from other international regulators and licensed operators. This will help verify and improve the existing data sources and identify additional datasets which can be used to improve understanding of the illegal market. But this data published so far does suggest that despite the persistent narrative that the illegal market has already exploded in scale, the engagement from consumers in Great Britain hasn’t yet followed.
The expectation remains though that the coming years will be more challenging. We don’t yet have data for what is going on since the changes announced in the Budget have come into effect. So no one at the Commission is being complacent – far from it. And that is why you are hearing so much on this work from me today and you have been from my colleagues at the Commission in recent months.
Because we are clear we need your help if we are to stop illegal gambling operators acting at scale.
I’ve already pointed to the wide cast of partners we have in achieving the results we have had already and we thank them for that. But we must go further. We will be looking to do more with payment providers going forwards, we want to see more from the social media giants too and as my colleague Tim Miller has said in recent months, we can see an opportunity for licenced operators to use their financial muscle to influence some of these other sectors as well.
Government is also a key part of the puzzle and in the UK, a Minister-led Illegal Gambling Taskforce has been set up and is already pushing forwards. The Commission is heavily involved as are many of the sectors and groups I’ve talked about already today. It’s vital they all lean in and play their part. Through the Taskforce, we are already pushing towards the publication of the first ever national risk assessment for the illegal market in Great Britain. The Minister is as determined as we are that the Taskforce delivers tangible results which is good news for the sector and good news for GB consumers.
Finally, as the last session of the UK Parliament ended, the Crime and Policing Bill became law. Its enactment will deliver new powers to the Gambling Commission in the fight against illegal online gambling. Going forwards we will be able to go after illegal sites’ IP addresses and domain names ourselves, strengthening our formal powers in a crucial way for the work ahead.
I know there is real concern across the gambling sector about the illegal market but what I have spoken to you about today I hope reassures you that the capabilities the Commission has and the plans we are developing are not a multi-million pound version of whack-a-mole. We increasingly know what and where the criminals are, we know how to frustrate them and we want to continue working with all of you to prevent them operating at scale.
But protecting the licenced market is not all about the strength or aim of the stick. We are interested in what we can do with the carrots too. And that brings me on to innovation.
You’ll have heard from Gambling Commission speakers before on how innovative we think the gambling sector is and from the time I’ve had so far observing the sector up close I can only agree. And we want to see the sector make the most of that in the time ahead. Delivering the best consumer experience that can be achieved will clearly help keep the paying public within the licenced sector and away from the criminals.
So for our part we are looking at what we can do to support you in that endeavour. We know that more and more consumers are showing interest in crypto – especially younger generations. So we have started discussions with our Industry Forum on how we can keep pace with Financial Conduct Authority (FCA) progress on crypto and look at what a potential path forward would be, to create a way for crypto assets to be more easily used as a consumer payment option for licensed and regulated gambling in Great Britain. This will take time but I’m sure you would all agree, getting it right so your businesses and your customers don’t end up in trouble is the right way to go about this.
We also know how important it is to keep our rule book as streamlined as possible. Whilst we can’t commit to this until we know where our fees position will land, following the Government consultation, we are looking at a strategic piece of work to review the impact, efficiency and burden of current regulatory requirements. This would be consistent with the UK Government’s wider regulatory reform agenda and is something that is being planned if we can resource it.
And finally, we want to hear your ideas too. Who better to know where you can improve the consumer offer than operators yourselves. So, if you have ideas to improve the customer experience, make it more positive, make it more competitive, we want to hear from you. The current statutory and public policy framework does place some limits on what can be achieved but it doesn’t stop us out of hand. So, if you have ideas that could deliver a better consumer experience, don’t be shy, please do reach out to us.
Thank you for listening to me today. It’s been great to be able to come out to Gibraltar again, in a new role, and give you my thoughts on where we are when it comes to the work we all have ahead on tackling the illegal market. The challenge is real, but if we remain clear sighted about the job in front of us and commit to working together, we can make a difference.
I’m intending to be around the Conference all day so please do come and say hello if there are things you would like to discuss. But I’m also more than happy to take any questions you might have now.
Thank you.
Last updated: 12 June 2026
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