Scratch:Lucky to Win

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“There are significant checks on individuals and businesses before a licence is granted,” he says. “The UK Gambling Commission has set out what it expects. If you want a licence in the UK, you need to meet those expectations.”

Bentley believes regulated operators are genuinely trying to do the right thing but says some mistakes could be mitigated through better automation and continuous monitoring. Enforcement statements also provide lessons that businesses should use to test their own exposure.

“It would be crazy to say that these cases are positive for the industry,” he says. “They will no doubt continue, but as an industry we need to try to reduce their frequency.”

About Scratch:Lucky to Win

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.

The regulator noted that several operators received “additional points for attention”, indicating that while these applicants met minimum legal thresholds, the KSA expected continuous improvements in compliance practices.

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“[At] above roughly 150 players per manager, personal knowledge stops scaling. The fix is not fewer players or more managers – it is showing each manager which few accounts actually need them today,” she added. 

Satisfaction with existing tools scored an average of 6 out of 10. Co-author Gali Hartuv, CEO and co-founder at WarriorLab described this “middling satisfaction” as “the most expensive kind”.

While VIP managers welcomed AI for prioritising their workload, the report suggested they remained cautious about delegating a final judgment to opaque automated systems.