Official magazine of the International Masters of Gaming Law
®
MALTA MARKET FOCUS
INTERNATIONAL MASTERS of GAMING LAW MAGAZINE
VOLUME 6 | NO. 2 | JUNE 2026
THOUGHT LEADING TRANSNATIONAL PERSPECTIVES FOR AN INTERNATIONAL ORGANIZATION
PLUS PREDICTION MARKETS IN EUROPE AND ELSEWHERE EUROPEAN TENSIONS OVER PLAYER CLAIMS HOW SUSTAINABLE IS THE SWEEPSTAKES MODEL?
REGULATORY STRATEGIES TO TACKLE THE BLACK MARKET INFLUENCER MARKETING IN ARGENTINA: A CRIMINAL JUSTICE APPROACH DATA PROTECTION RULING TAKES THE HEAT OFF MARKETERS IN UK ALL CHANGE: GAMBLING LAW INSIGHTS FROM AUSTRALIA, FRANCE AND UKRAINE ...AND MUCH MORE!
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IMGL MAGAZINE | JANUARY 2023
MALTA’S FATF GREY-LISTING IMGL OFFICERS 2026
Officers of IMGL for 2025
PHIL SICUSO Assistant Treasurer BOSE MCKINNEY & EVANS, LLP INDIANAPOLIS +1 317 684 5265 PSICUSO@BOSELAW.COM
PETER KULICK 1 st Vice President DICKINSON WRIGHT PLLC LANSING, MICHIGAN +1 517 487 4729 PKULICK@DICKINSONWRIGHT.COM MARC DUNBAR President JONES WALKER TALLAHASSEE, FLORIDA +1 850 214 5080 MDUNBAR@JONESWALKER.COM COSMINA SIMION Executive Vice President WHSIMION & PARTNERS BUCHAREST, ROMANIA +40 31 420 6225 COSMINA.SIMION@ WHSIMIONPARTNERS.RO
RON SEGEV Secretary SEGEV LLP TORONTO / VANCOUVER +1 604 629 5402 RON@SEGEVLLP.COM
DR. SIMON PLANZER Assistant Secretary PLANZER LAW AG ZUG, SWITZERLAND +41 41 512 42 82 PLANZER@PLANZER-LAW.COM
ERNEST C. MATTHEWS IV Vice President, Affiliate Members INTERNET SPORTS INTERNATIONAL LAS VEGAS, NEVADA +1 954 478 8758 ERNEST@ISISPORTS.COM BIRGITTE SAND Vice President, Affiliate-Regulator Members BIRGITTE SAND AND ASSOCIATES COPENHAGEN, DENMARK +45 24 44 05 03 BS@BIRGITTESAND.COM BECKY HARRIS Vice President, Educator Members WILLIAM S. BOYD SCHOOL OF LAW AT UNLV LAS VEGAS, NEVADA +1 702-324-0404 BECKY@BECKYHARRISNV.COM
MATTHIAS SPITZ 2 nd Vice President MELCHERS LAW HEIDELBERG +49 62 2118 50141 M.SPITZ@MELCHERS-LAW.COM
KATE LOWENHAR-FISHER Treasurer EXECUTIVE VICE PRESIDENT, CHIEF LEGAL OFFICER, EVERI HOLDINGS INC +1 800 566-2087 KATE.LOWENHARFISHER@EVERI.COM
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IMGL MAGAZINE | JUNE 2026
PRESIDENT’S WELCOME
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Partnerships mean a world of opportunities for members
MARC DUNBAR President INTERNATIONAL MASTERS OF GAMING LAW
I t will not have escaped your attention, I’m sure, that we recently announced a three-way partnership involving IMGL, IAGR and SBC which will run for at least the next three years. The deal follows news shared with members in D.C. that we have signed a three-year sponsorship of IAGR. Separately these arrangements are significant; together they mark a big new phase in our development as an organization and what we are able to offer members. It has long been our plan to build on already good relations with IAGR. Being close to regulators helps deliver on our education mission as well as being good business for our members. Linking the deal with a tie-in to one of the largest and fastest-growing media companies in our industry means the relationship can be projected onto a global stage with big benefits all round. The deal is still quite new, but we are already planning for an IMGL delegation to attend IAGR’s upcoming conference in Lima, Peru. We will also be partnering on legal tracks and Masterclasses for all of SBC’s portfolio of summits and conferences bringing much greater visibility for IMGL, our sponsors and our members. It is on this last benefit that I would like to focus in this, our members’ magazine. As many of you will attest, it has always made sense to become a member of IMGL, but as its President, I would say that. Now, with the announcement of these new partnerships, I firmly believe the IMGL value proposition is stronger than ever. The sponsorship of IAGR will embed IMGL at the heart of international gambling regulation delivering on our promise to members of shaping the future of gaming law.
Our long-standing relationship with SBC has already positioned IMGL as their go-to source of legal content. This new deal takes that to the next level with official recognition of IMGL and our members at all their industry events, within their Leaders magazine and including regular appearances on their growing iGaming Daily podcast. The platform this offers to members is truly global and I hope each one of you will benefit. The announcement goes hand-in-hand with work being done elsewhere by our committees, especially our combined Emerging Markets and 2040 Committees. This will see the selection of ambassadors to represent IMGL at industry events. We see this as the missing piece of the puzzle and the step which converts IMGL presence into outreach to potential new members. Ambassadors will be expected to actively promote IMGL membership at events they attend, sitting on Masterclasses or hosting dinners. They will be asked to identify potential members, introduce them to the organization and walk with them on their journey towards membership. They will be supported in these efforts by our executive, with promotional materials and, where appropriate, with a financial contribution towards costs. We are also planning ways to recognize ambassadors within the IMGL organization. It is an exciting time to be an IMGL member and now we have the means and opportunity to share that message more widely. I look forward to working with each of our members to explore how you can play your part. Marc Dunbar
IMGL MAGAZINE | JUNE 2026
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EDITORIAL
Transnational perspectives for an international organization
T
SIMON PLANZER PHD Editor in Chief IMGL MAGAZINE
he International Masters of Gaming Law is a global organization. From the launch of the IMGL Magazine, I was determined that the international ambition be reflected in its pages. Indeed, in my very first editorial in April 2021, I wrote: “This first edition sets the standard for what I intend will be a truly worldwide publication with contributions from all continents and which addresses a global readership interested in gaming law” Alongside this goal was a profound desire to move away from quick fix jurisdictional updates and to “seek out and publish articles that illuminate the regulatory debates in the gaming industry with evidence,” as I outlined in my editorial in January 2022. It is always exciting to review each edition of the IMGL Magazine and to watch it come together in ways which I believe continue to meet the
international ambition. In this edition, we publish articles contributed by authors from five different European countries, three different Latin American countries and from Australia. Our organization, while founded in Las Vegas, continues to attract an international membership base, which I find important to recognize and honor. The industry is a truly global one and there are lessons to learn from right across the world. It is accordingly always a particular pleasure to be able to publish articles, which offer a refreshing perspective that shows relevance well beyond the jurisdiction of the author. You, dear readers, can look forward to discovering a broad variety of perspectives in this edition: highly topical market updates from France, Ukraine and Australia; a fascinating study on ways how AI could significantly affect the current debate around prediction markets; an insightful examination
Contents 6
Can artificial intelligence shape the future of prediction markets as financial dynamics?
12 16 24 30 36 42 48 54 58
Riding the wves: 1-on-1 with Gagbit's Guy Fietz
Betting on the future: Gambling regulation in Australia in 2027 and beyond
Tensions in Europe over player claims
Regulatory design & the online gambling black market: four determinant failures Sweepstakes: tension between virtual gaming and regulated gambling
Will prediction markets come to Europe?
Influencers and illegal gambling: Argentina’s criminal enforcement model Regulating gambling in France in the digital age: from casinos to Web3 RTM v Bonne Terre Ltd and another: the Court of Appeal sets the standard for consent
62 Navigating the evolution: a comprehensive review of Ukraine’s gambling sector transformation
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IMGL MAGAZINE | JUNE 2025 IMGL MAGAZINE | JUNE 2026
EDITORIAL
of the regulatory paradox where unintended consequences of poorly designed regulatory practices support the growth of the black market. Elsewhere, we have a comparative study of regulations across Europe to answer the question: Where next for prediction markets? A senior colleague looks at the fine print of recent rulings from the Court of Justice of the EU to establish where exactly this leaves the enforceability of player claims in Austria and elsewhere. Finally, we have a groundbreaking approach to controlling influencer marketing, which sees them recruited to the cause of responsible gaming. Let me wrap up this editorial by thanking all authors that have submitted and continue to submit manuscripts to our review process. Your efforts significantly contribute to IMGL’s educational mission. And your willingness to onboard editorial feedback contributes to the quality and relevance of this publication. With such great support by authors from around the world, it is a true pleasure to continue to foster the transnational perspective of the IMGL Magazine and the international reach of our organization
Yours, Simon planzer@planzer-law.com
To access our extensive archive of expert gaming law articles visit www.IMGL.org/publications
IMGL Magazine is owned, published and distributed by: The International Masters of Gaming Law PO Box 27106, Las Vegas, NV 89126 USA The IMGL is a domestic non-profit corporation registered in Nevada, U.S. with registration number NV20121147120 Editor in Chief: Simon Planzer PhD, planzer@planzer-law.com Publication & Marketing Committee: Co-chairs , Simon Planzer (Publications), Ali Bartlett (Social Networks & Digital) Members : Luiz Felipe Maia, Daniel McGinn, Luis Carvalho Staff : Phil Savage, Brien Van Dyke Head of Publications: Phil Savage phil@IMGL.org Design and production: SportBusiness Communications. Copyright: All rights reserved to IMGL. No part of this publication may be reproduced or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise without prior permission from the publisher. The articles expressed in this publication do not necessarily reflect the views of IMGL but those of the authors. The publisher and editor do not accept any liability for the contents of the authors’ contributions.
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IMGL MAGAZINE | JUNE 2025 IMGL MAGAZINE | JUNE 2026
AI AND PREDICTION MARKETS
Can artificial intelligence shape the future of prediction markets as financial dynamics? THE PREDICTIVE POWER OF AI MAY SHIFT EVENT CONTRACTS AWAY FROM BETS MAKING THEM MORE LIKE THE FINANCIAL INSTRUMENTS THEY CLAIM TO BE ARGUE JUAN CAMILO CARRASCO AND LIZETH ACELAS
T he rise of prediction markets has reopened the debate over the boundary between gambling and financial markets. While in the United States the regulatory discussion continues to oscillate between treating these products as bets or as financial instruments, this article examines the impact of artificial intelligence on that debate. Through the development of tools based on machine learning and advanced analytics, AI may progressively reduce the element of chance by strengthening predictive capabilities and informational asymmetries between participants. From this perspective, such evolution could shift prediction markets towards being understood as financial vehicles, unless the gambling industry develops regulatory alternatives capable of responding to these new dynamics.
Introduction Over recent years, prediction markets have become one of the most sensitive debates within both the gambling industry and financial markets. In the United States, the regulatory discussion has largely focused on whether these products should be understood as traditional bets or as financial instruments based on information and economic projections. The debate remains open and is currently before the courts. As noted in the recent NEXT article “The Great Divide” 1 , those defending these markets as part of the financial sector argue that they share important similarities with traditional financial mechanisms, including trading activities and the analysis of future events, while also attracting a different type of consumer from the traditional gambling user. However, much
1 NEXT.io, “The Great Divide”, March 2026.
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of this discussion continues to develop on the assumption that these markets remain fundamentally dependent on chance. Within this debate, one element has still received limited attention, namely the impact of artificial intelligence, particularly machine learning. As these technologies evolve, predictive systems are becoming capable of processing vast amounts of information, identifying complex patterns and developing increasingly sophisticated probabilistic models. Several recent studies on machine learning applied to sports betting and prediction markets show that these systems not only improve the accuracy of certain predictions but also identify inefficiencies within markets. This raises an important question as to what happens when uncertainty no longer depends solely on human intuition or basic analytics but instead becomes increasingly influenced by advanced computational capabilities. This article argues that artificial intelligence does not entirely eliminate chance. However, due to its rapid evolution, it may progressively transform the way uncertainty is distributed within certain gambling verticals. In environments driven by large volumes of data and real-time analytics, competitive advantage may begin shifting away from traditional chance and towards predictive dynamics, information processing and the analysis of algorithmic asymmetries. From this perspective, the evolution of AI could reopen, at least from a technical and regulatory standpoint, the discussion as to whether certain gambling verticals are gradually moving closer to structures commonly associated with prediction markets under a financial market logic. The predictive power of AI Those defending prediction markets from a financial perspective argue that these products share important similarities with certain dynamics commonly found in trading activities and derivatives markets. One of the main arguments supporting this position is that, unlike traditional gambling, participants may buy, sell or close positions before the final event occurs, much like certain financial instruments. This ability to manage positions in real time, while generating economic benefits, has become one of the main elements used to distinguish these models from traditional concepts of chance. 2 Standford University, “Artificial Intelligence Index Report 2025”.
Within this logic, information plays a central role. In many trading environments, participants seek advantages through the analysis of data, trends, news, market behaviour, political developments and future projections, among other factors. A similar dynamic can be observed in certain prediction markets, where participants no longer act solely on intuition or entertainment, but rather on the interpretation of information and probabilities. As noted in NEXT’s article “The Great Divide” , one of the most common arguments advanced by supporters of these models is that their users behave more like traders or specialized analysts than traditional gambling consumers. Closely linked to the role of data and the way it is processed within these markets, another element emerges which could substantially transform this discussion, namely the accelerated evolution of artificial intelligence, particularly through systems based on machine learning. According to Stanford University’s 2025 AI Index Report, the growth of these models over the last decade has been exponential. The report states that “parameter counts have risen sharply since the early 2010s, reflecting the growing complexity of their architecture, greater availability of data, improvements in hardware, and proven efficacy of larger models” 2 . The AI Index Report also highlights significant improvements in benchmarks designed to measure complex reasoning, programming and advanced problem-solving capabilities. Between 2023 and 2024, results achieved by AI models increased considerably across these types of tests. In certain scenarios, language model-based agents even outperformed humans in specific programming tasks under limited time constraints. It is also important to highlight the increasingly sophisticated predictive capabilities being developed in real-world scenarios. The same report refers to models such as “Aurora” and “GenCast”, designed for advanced climate forecasting and capable of generating highly accurate predictions relating to cyclone trajectories, air quality, ocean waves and complex weather phenomena at significantly lower computational costs than traditional systems. In other words, modern machine learning systems are no longer limited to automating tasks or processing information, but are increasingly capable of
IMGL MAGAZINE | JUNE 2026
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AI AND PREDICTION MARKETS
optimizing complex predictive processes through the large- scale analysis of data, historical patterns and dynamic probabilities. Nevertheless, the gambling industry has not remained isolated from the use of artificial intelligence systems based on machine learning. Initially, many of these tools were used in marketing processes, user segmentation, customer interaction and commercial optimisation within digital betting platforms. More recently, the evolution of these systems has also started to play an important role in responsible gambling initiatives and the early detection of at-risk players. A study developed by researchers from the International Gaming Institute at the University of Nevada Las Vegas (UNLV), Harvard Medical School, the University of Calgary, the University of Sydney and Washington State University notes that artificial intelligence systems have become central tools in harm prevention efforts within the gambling industry. The study highlights that one of the main attributes of machine learning lies in “…its ability to learn complex and nonlinear relationships in the data” 3 , allowing these models to “…target players according to markers defined by both their gambling patterns…” 4 , thereby enabling the detection of potentially problematic gambling behaviours through the individualised analysis of user conduct.
extract insights from large volumes of data, with the goal of improving the accuracy of predictions in the ever-evolving landscape of college football.” 5 The research compiled thousands of historical data points derived from sports statistics and Las Vegas betting lines, subsequently building a database containing more than 1,700 variables related to performance, historical results and betting behavior. Based on this information, the researchers trained different machine learning models, including neural networks, in order to compare their predictive capabilities against the betting lines traditionally used by the industry. The study concluded that tools such as lasso regression and feature selection 6 , both commonly associated with machine learning techniques, significantly improved the accuracy and robustness of predictive models. However, the study also demonstrated that Las Vegas betting lines constituted one of the strongest predictors within the model, to the extent that removing this variable considerably reduced the performance of the analysed systems. AI in the sports betting context A study entitled “A Systematic Review of Machine Learning in Sports Betting: Techniques, Challenges, and Future Directions” 7 states that “…machine learning has significantly impacted the sports betting landscape by improving both the accuracy of predictions and the efficiency of betting strategies” , further noting that these techniques “…have been employed to identify mispriced odds offered by bookmakers, presenting opportunities for savvy bettors to capitalize on these inefficiencies” . This demonstrates how artificial intelligence is beginning to reshape the traditional understanding of chance within sports betting, opening the discussion as to whether the modern bettor increasingly resembles an analyst of information and
Another example of these predictive capabilities can be observed in gambling verticals such as sports betting. A relevant example is the study developed by Luke Boll, a researcher at the University of Michigan, on neural networks applied to predicting outcomes in college football. In this paper, the author states that “In recent years, neural networks have emerged as a powerful tool for predicting sports outcomes due to their ability to learn complex relationships between statistical inputs and game outcomes. These challenges have led to the development of various prediction models that utilize machine learning and statistical techniques to 3 Kasra Ghaharian et al, “The Need for Benchmarks to Advance AI-Enabled Player Risk Detection in Gambling” , International Gaming Institute (2025). 4 Ibid 5 Boll Luke, “Gridiron Genius: Using Neural Networks to Predict College Football” , Michigan University 6 Lasso regression is a statistical technique used to identify relevant variables within large volumes of data, while feature selection refers to the process of identifying and retaining the most useful variables to improve the predictive performance of a machine learning model. 7 Manassé Galekwa René et al. “ A Systematic Review of Machine Learning in Sports Betting: Techniques, Challenges, and Future Directions” (2024)
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variables, similar to certain profiles within the financial sector, where data processing capabilities and analytics may partially reduce uncertainty. Nevertheless, it is essential to distinguish prediction markets from sports betting based on the nature of the underlying event. In prediction markets, the object of prediction is generally linked to structural, economic, political or social variables whose evolution may be modelled through aggregated information and rational analysis, allowing uncertainty to be progressively and cumulatively reduced. By contrast, sporting events contain an irreducible element of randomness associated with inherently unpredictable factors, including real-time human decisions, errors, physical conditions, refereeing decisions and unforeseen events, all of which limit the scope of any predictive system. For this reason, although artificial intelligence may significantly improve accuracy within sports betting, we believe it is still incapable of eliminating chance in these events. It may therefore become necessary to propose a regulatory test based on at least three variables for classification purposes, namely (i) the degree to which chance may be reduced, (ii) the role of information and predictive capability, and (iii) the possibility of actively managing positions. Another regulatory alternative may lie not necessarily in the creation of entirely new legal categories, but rather in the reinterpretation or adaptation of existing industry models, such as certain exchange betting schemes whose operational logic increasingly resembles dynamics commonly associated with prediction markets. This may represent only the beginning of AI’s impact on the gambling industry. As previously noted, the evolution of these technologies is occurring at remarkable speed, raising the possibility that gambling environments may soon involve artificial intelligence agents with a far more active role in digital interaction through the autonomous execution of tasks based on pre-established prompts. In this context, artificial intelligence is already beginning to generate new asymmetries between users with access to
advanced predictive processing tools and those who continue to participate solely through traditional human capabilities 8 . The discussion therefore moves beyond automation itself and towards the possibility that certain participants may develop structurally superior analytical advantages within prediction markets and gambling verticals, potentially disrupting the balance between users. At the same time, advances in algorithmic personalisation models are transforming the way users interact with digital betting platforms. The article “AI Personalization and Its Influence on Online Gamblers’ Behavior” 9 notes that modern machine learning systems are already capable of dynamically adapting content, recommendations and digital experiences based on each user’s individual behavior, thereby creating highly personalised environments in real time. This raises the possibility of environments where bettors are no longer simple artificial intelligence agents, as is already the case today, but highly specialised and continuously trained systems capable of developing predictive and analytical advantages within increasingly personalised betting markets. This demonstrates that the impact of machine learning within gambling is no longer limited to operational, commercial or responsible gambling processes. It is progressively transforming structural dynamics within the sector, as well as the traditional understanding of the gambling consumer itself. The growing ability of these systems to process vast amounts of information and generate predictive advantages is already having a direct impact on highly data-intensive verticals such as sports betting. This phenomenon also appears to impacting the profile of users within certain gambling verticals. The traditional consumer, historically driven mainly by intuition, entertainment or chance, is beginning to coexist with participants using advanced analytical tools, data processing systems and predictive models to optimise decision-making. It may even mark the beginning of competitive dynamics between human users and AI agents capable of directly interacting with betting platforms. The accelerated evolution of machine learning, together with
8 Tshilidzi Marwala and Evan Hurwitz “Artificial Intelligence and Asymmetric Information Theory” , University of Johannesburg 9 Mihai Florin et al. “AI Personalization and Its Influence on Online Gamblers’ Behavior” . Review Behavioral Sciences”. (2025)
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the future development of increasingly specialised artificial intelligence agents and systems, will likely create new regulatory and conceptual challenges for the gambling industry. In particular, it may require a reconsideration of how uncertainty and chance are understood within certain digital markets. This also represents a challenge from a regulatory perspective, given the degree of agility and flexibility that future frameworks may require in response to the transformations expected within the industry. These developments are already raising new technical and regulatory questions. If certain artificial intelligence tools become capable of generating increasingly sophisticated predictive advantages, it becomes necessary to examine whether gambling verticals such as sports betting or eSports, both highly data-intensive environments well suited to predictive AI systems, still operate under traditional concepts of chance or are moving progressively closer to information and prediction markets more commonly associated with financial market dynamics. It may also become necessary to establish clearer rules governing the use of artificial intelligence within gambling platforms, both from the perspective of operators and users, including potential obligations relating to transparency, the identification of automated systems and the use of certain predictive models. In other words, the future regulatory challenge may not lie solely in controlling the use of artificial intelligence, but rather in determining the extent to which these technologies can alter the balance of uncertainty upon which the traditional concept of chance has historically been built. Conclusion The evolution of artificial intelligence is inevitably confronting the gambling industry with new challenges, particularly within verticals where prediction and variable analysis are becoming increasingly valuable. In this context, the discussion no longer appears limited to the
existence of a random element, but rather to the impact that analytical and computational advantages may have on users interacting with betting operators, and whether both the industry and regulation are prepared for the emergence of a far more sophisticated user seeking to reduce chance and uncertainty. This transformation may also strengthen some of the arguments advanced by those who consider prediction markets to be more closely aligned with financial dynamics than traditional gambling. If certain users increasingly rely on predictive tools, automation and sophisticated information analysis, it becomes necessary to question whether traditional gambling regulation remains suitable for these new realities or whether alternative regulatory approaches may eventually be required. Everything suggests that, in the short and medium term, new regulatory demands will emerge concerning the use of artificial intelligence within the gambling industry. Issues such as transparency, the use of AI agents, advanced predictive tools, personalisation and equality of conditions between users are likely to generate discussions that will progressively reshape the way the sector is understood and regulated. Given the speed of this transformation, both regulators and the industry itself may need to adopt a more proactive approach. Those capable of understanding the implications of these technologies at an early stage will likely shape how markets understand chance and prediction in the years ahead. Otherwise, there is a risk that certain economic dynamics may progressively migrate towards regulatory frameworks more closely associated with financial or technological sectors, moving part of this discussion outside the traditional boundaries of gambling regulation. What is clear is that artificial intelligence is here to stay, as are prediction markets. “...what you resist not only persists, but will grow in size.” Carl Jung
JUAN CAMILO CARRASCO
Managing Partner, SORA Law For more information contact juan.carrasco@soralaw.co +57 310 769 5580
LIZETH ACELAS Associate, SORA Law
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IMGL MAGAZINE | JUNE 2026
BEATING THE BLACK MARKET
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IMGL MAGAZINE | MARCH 2026
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ONE-ON-ONE
Riding the waves GUY FIETZ , CEO AT CANADIAN PAYMENTS PROVIDER GIGADAT, OUTLINED TO EDITOR-IN CHIEF SIMON PLANZER HOW HIS COMPANY STAYS AT THE FRONT OF A HIGHLY COMPETITIVESECTOR
Simon Planzer: Let's start with the Gigadat story. How did the business come about? Guy Fietz: We started out in the telecoms space, operating third-party billing where we established the first clearing house in Canada. We ran that business for around 15 years but saw things becoming more difficult. The big carriers were commoditizing everything and taking more and more of the revenue share. We could see a slow death in that in that market so I started to look at what alternatives there might be out there. We developed a direct debit solution and tried to find a sweet spot in different markets. Eventually we alighted on gaming and started seeing some uptake there so we refocused our efforts and the rest is history. Over the next several years we became a market leader and we have managed to retain that lead in the Canadian market. We've grown exponentially year over year for the last 10 years now and gone from an infancy level operation to a the sophisticated, advanced, and highly automated platform that we are operating today. In the process we have gone from around eight to 10 employees to 150 employees, and we're now processing billion of dollars a year. SP : Was there a key moment where you thought, this is going to be a winner?
GF : There really was. We were searching for multiple markets that would adopt the online debit solution and gaming was one that picked it up very quickly. We saw a couple of big-name brands out there come on board. Their original forecast was something to the effect of $500,000 in transaction value per month for the first year. But within the first two months that had grown to over $5 million in transaction value, and that was the point we knew we really had something. The adoption rate was just completely vertical, the consumers loved the option in the cashier pages, and so we knew we were on to something big. SP: Some people may say payments is payments, it's all the same! It's processing transactions. How can a payment provider gain a competitive advantage and stand out in that market? GF: Our philosophy has always been to provide a consultative service and that’s what makes us different. A lot of the big processors out there are on “set it and forget it” mode. Once a merchant is integrated, then it's up to them to utilize the tools available and access the reporting data. Whereas we're always consulting with our merchants, trying to find out what they're looking for, what their needs are and maybe what
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ONE-ON-ONE
1 on 1
they don’t even know they need. We have also invested in our development capability. We have a development team of 55- 60 in-house developers building tools, features and functions for our merchants. We're always striving to automate, automate, automate. So even though we still have that hands- on relationship with the merchant, in the background we’re running highly automated systems, and that's one of our core strengths. Another important part for us has been our 24/7 CSR center. Sometimes customers encounter problems or they get confused, and at that point they reach a brick wall with most payment service providers in this marketplace. That forces the consumer to try to figure out their own issue. What happened? How come I didn't see the money transfer? Whereas we'll hand hold the consumer through our CSR centers; we'll see that a person has been having difficulty and we'll either communicate directly with them or through a chat bot. By hand holding the consumer who has been having issues we see an eight to 10 percent uptick in completed transactions overall in a month. When you're dealing with tenths of percentages making a difference to the merchant overall, that's a huge difference. That's a big differentiator for us. SP: At the end of the day, there's an important similarity with the online gaming operators. It's all about the customer experience, right? GF: Yeah, we're doing what we can on our end to facilitate that seamless experience and allow that consumer to move their funds in and out as fast as possible. Speed is critical in the marketplace and compared to the performance speed of our competitors, typically we're always faster on the ins and outs. SP: Gaming is a highly regulated sector which brings a lot of compliance requirements for payment service providers. How do you deal with that in a way that it doesn’t create friction for the consumers with, for example, false positives? GF: We're fairly unique in that our Canadian network is just that: it's a Canadian only network. It’s a closed loop
system which means our transactions are between Canadian consumers, by and large. So, when it comes to financial crime, sanctions and blacklists, I'm not saying there's nobody in Canada that is blacklisted, but for a bad actor to get into our system, they would have to be a Canadian resident and that does make it easier for us. I agree, the scrutiny is becoming tighter and changes can happen overnight, so all market players have to be really aware of that compliance environment. We follow all of the blacklists and the AML checks, we adhere to the bank lists and the network interact lists. And we just don’t allow those bad actors in. You mentioned false positives, and we do have the ability for an individual to provide their personal ID in real time, so they can make attest to the fact that they're not a blacklisted individual. We review individuals who come forward with a misidentification issue, and we can typically resolve that very quickly. The bigger issue are the blacklisted countries and ultimate beneficial ownership rules, but we have very stringent due diligence processes. All of our onboarding procedures require corporate due diligence, UBO identification. So, so we're really tight in that area. SP: What are the big developments in gaming and payments that are keeping you awake, or where you see the opportunities? GF: In Canada it’s really the change in the provincial regulatory frameworks. Regulation is becoming more and more stringent, which we're fine with, but it does create potential friction within the operators. What we strive for is to maintain the customer experience, and without interrupting the customer experience. SP: Regulators everywhere are constantly raising the bar with ID authentication, age verification, geo location and the rest. Have you constantly adapted your product to meet those requirements? GF: I’ve got to give credit to our technical and operational staff here. We're very agile, all of our platforms are in house,
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SP: Regarding regulation, while it is necessary to some extent, it can also just be a burden, let’s face it. Have you come across regulations in the field of payment services where you wonder: how does that help the consumer? How does that even protect the consumer? GF: Sure. There are several regulatory regimes out there now, where I guess I understand from a governmental standpoint, they believe they're doing what's best for Canadian citizens. That being said, we’re largely talking about restrictions so, you have to ask, if they're not helping the consumer, who are they helping? Is it helping retailers? I'm not so sure. It's adding a lot of weight and a lot of responsibility to transactions from start to finish. Each touch point needs to absorb that responsibility, from the banks to the networks to the payment facilitators to the consumers themselves. We're following all the different regulatory aspects, we report to FinTrack regularly on transactions that trigger reporting requirements, but I'm not so convinced that some of the new regulatory aspects are helping. SP: Crypto is clearly going to be on any payment provider's to-do list. Thinking about it from a regulatory side, how do you think gaming regulators should proceed to open up the gaming market to crypto, given that it's part of the world that we live in? GF: Crypto is really interesting and we see it as a huge opportunity in the gaming space. There are a bunch of early adopters and while not many companies want to be on a bleeding edge, being on the leading edge is great. We we've been dipping our toe in the water for a while. Where some of our merchants around the globe are requiring to be paid out in crypto, we've been facilitating that for a number of years now. We're pretty comfortable with the processes and we’re dealing with a pretty stable environment now. In the past there have been a lot of unstable environments, and you had to choose your exchanges carefully. We've always managed to work with a stable exchange so, never had any issues there.
and our developers are always looking to improve and adapt to the different frameworks. Whether that’s end user credit limits or frequency issues we look for ways to protect the consumer, but also mitigate risk with the operator itself by providing alerts and being in concert with them on those alerts and fraud. We're not a regulator, but being intrinsic to the movement of money, we do have our fraud controls, red flags and alerts which are communicated with operators. SP: Fraud and financial crime is one area; the black market is perhaps another. We hear regulators talk about recruiting all parts of the ecosystem in gaming to fight the black market. Is that something that you have been asked to do, or are keen to do? What's your view on how payments providers can get involved? GF : As far as the black market goes, we're very stringent in our onboarding processes and we only work with licensed operators. Another aspect of compliance concerns gray markets. These are sanctioned countries that are not necessarily blacklisted, but are maybe on the FATF grey list. We know that that can happen due to a regulatory change that puts an area offside, however, if that country or the regulatory authorities are determined to maintain compliance, then we know they're going to work towards removing that gray status and we watch that very carefully. We have a no-fly zone in the black areas, so we steer well away from those. The other interesting thing for us is the First Nation part of the market. That's undefined as far as we’re concerned in Canada, so you could call it a gray market area. We've got positive legal opinions regarding it, but it's somewhat of a contentious area for the provinces as well, so we acknowledge it but we don't promote it. I think, the situation will be resolved as each of the provinces move towards a regulatory framework. Ontario's had great success, Alberta is about to launch so we look forward to the rest of the provinces coming into that same regulatory framework.
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Now you've got evolving consumer awareness, you've got all the big investment banks now participating in crypto, you know, Morgan Stanley, JP Morgan, BlackRock, etc. You've got wider adoption, you've got recommendations coming from very large investment banks for consumer participation in their in their wealth portfolios, etc. So, I think we’ll see wider adoption coming very shortly now, especially with Trump's new Act coming in. All the banks are opening up to crypto in the United States, and Canada's following, so you're going to see a very wide consumer-based adoption across North America. That’s going to mean it takes in everyday transactions, and you've got early adopters that will be looking to standardize offerings with stable coins being the obvious one. Canada just launched the CADD, its own digital currency and we're looking to provide that solution to the Ontario market, for starters, and then roll it out to Alberta. I think stable coins are the way to go, whether it's a pay in or pay out scenario. For now, consumers will still roll back to fiat currency, most likely on their settlements, but to play with crypto, knowing that it's pretty much a dollar for dollar transactional value, I think that's going to bring a lot of confidence in the consumer in the utilization of crypto. I am very excited about cryptocurrency adoption, and I'm interested to see what kind of adoption there will be in the gaming side as a standard. Because I do think it will become standard, much like when we first introduced the direct deposit solution in Canada. SP: You have a strong focus on the Canadian market: the slogan on your website is “Connected with Canadians”. What are the advantages of focusing just on the Canadian market when you have another huge market right next door? GF: The Canadian market is actually a very exciting market. It punches way above its weight from a user standpoint. Everyone is well educated in the market and there are not a lot of bad actors. Of course, the limiting factor is the actual size of the market. From a global standpoint, it is a smaller population, but, as I say, it punches above its weight, and as a consequence garners interest from global operators. As we’ve seen each province adopt regulated gaming, that has
generated growth and, as the market leader, we’re in a good spot to keep growing with the market. SP: Canada has a sizeable Francophone population. Are there any plans on your side to expand to the French-speaking world beyond Canada? GF: We have many European-based customers and a European-originated salesforce. We've got a base now in Marbella, Spain, with a sales and marketing team there as well which helps a lot. But as far as expanding our consumer base into a global market, currently, no plan. We do have plans to look at a global crypto solution for the gaming market, and we'll see how that develops. We're looking at that roll out probably within the year. SP: Gigadat is a sponsor of the IMGL autumn conference in Paris and we're delighted to have you on board. I wondered what you were looking forward to about attending the event. GF: That is going to be a spectacular event and I'm really looking forward to it. It’s important to be in tune with the legal aspect and being able to have some discussions with legal representatives is always very interesting. Just to hear what that part of our industry is focused on and what they're seeing, it’s great to get those valuable insights over a nice dinner. And, of course, what better place than the Eiffel Tower? That's going to be exciting, and we're really looking forward to it. SP: You mentioned your 24/7 CSR, and that just reminds us all that this is a 24/7 business. You have clients all over the world, you've got customers who are playing at all different times. There must be a personal temptation to be always on. How to you take a break and switch off from the business? GF: I really love the water. I've got a boat, actually a couple of boats. I've got an 80-foot Sun seeker out of Vancouver and just love to get out on the water with friends and family and I get to be captain. I recently acquired a little fishing boat, and that's my little adventure now. Heading up the West Coast to catch some salmon, that's always an entertaining day, for sure.
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REGULATION IN AUSTRALIA
Betting on the future: Gambling regulation in Australia in 2027 and beyond MORE THAN 1,000 DAYS AFTER THE RELEASE OF A KEY REPORT, THE AUSTRALIAN GOVERNMENT'S NEWLY PUBLISHED RESPONSE ADDRESSES ONLY SOME OF ITS RECOMMENDATIONS FIND JAMIE NETTLETON, BRODIE CAMPBELL AND JAK YASUDA
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recommendations from the Murphy Report. Part III details the key reforms set out in the Bill. Finally, Part IV comments on whether the Bill is likely to be effective at minimising gambling harm in Australia The Murphy Report On its release in June, 2023, the Murphy Report 4 was hailed as a landmark report on gambling reform in Australia. It highlighted the impact of online gambling on Australians, noting that ‘Australians outspend the citizens of every other country on online gambling’, losing AUS$25 billion every year. The recommendations made in the Murphy Report apply a ‘public health lens to online gambling to reduce harm across the whole Australian population’.
Introduction The gambling industry in Australia has been in a state of turmoil over the past several years. Major casinos in Sydney, Melbourne, Brisbane and Perth have been subject to considerable scrutiny – and in some cases oversight – due to failures in their respective compliance regimes; 1 millions of dollars in fines have been issued by the Australian Communications and Media Authority (ACMA) in respect of gambling operators’ breaches of their obligations; 2 and numerous measures have been taken to reduce the harm caused by gaming machines. 3 One of the most important catalysts for the reforms in Australia was the 2023 ‘You Win Some, You Lose More’ report (the Murphy Report or Report). The Murphy Report is the final report of the Standing Committee on Social Policy and Legal Affairs’ ‘Inquiry into Online Gambling and Its Impacts on Those Experiencing Gambling Harm’, chaired by the late Peta Murphy (Inquiry). The Murphy Report made 31 recommendations to reduce harm and drive government action in respect of gambling in Australia. Despite this aim, and despite the Murphy Report urging that swift action should be taken, the Australian Government did not announce its response until 12 May, 2026 – over 1,000 days after the report’s release. Shortly after announcing its response, the Government released an Exposure Draft of the Interactive Gambling Amendment (Gambling Reform) Bill 2026 (the Bill) on 29 May, 2026 with the final bill expected to be tabled in Parliament in July, 2026. Despite the time it took to formulate, however, the Government’s response has been criticised by parties on both sides of the debate. This article critically analyses the Bill, and considers whether it will be effective at achieving its intended objectives. This article proceeds in three parts. Part II sets out some of the key
Some of the key recommendations are set out below:
National gambling regulator
Responsibility for gambling regulation in Australia is currently divided between the federal government and state/territory governments. Submissions to the Inquiry highlighted that the various regulators across Australia currently operate in silos. Other submissions pointed out that, under the Australian Constitution, only the federal government has the ‘levers and authority to effectively introduce nationally consistent regulations in line with consumer expectations’. Despite this, other submissions emphasised that a national regulator would not have the same flexibility that state and territory regulators have by ‘being able to choose between a coordinated or unique approach’.
In light of the consultation, the Murphy Report ultimately
1 ‘The Star’s Manager’s Term Extended for Further Six Months’, NSW Independent Casino Commission (Media Release, 1 April, 2026) <https:// www.nicc.nsw.gov.au/news-and-media-releases/star-manager%E2%80%99s-term-extended-for-further-six-months>; The Star Entertainment Group, ‘Disciplinary Action and Appointment of Special Manager in Queensland’ (ASX Announcement, 9 December 2022); ‘About the Special Manager: An Overview of the Office of the Special Manager’, Vic.gov.au (Web Page, 28 June,2024) <https://www.vic.gov.au/about-special-man- ager-melbourne-casino-operator>; Paul Papalia, ‘Casino Licensee Found Suitable by Racing and Gaming Minister’ (Media Release, 8 July, 2025) <https://www.wa.gov.au/government/media-statements/Cook%20Labor%20Government/Casino-licensee-found-suitable-by-Racing-and-Gam- ing-Minister-20250708>. 2 See, eg, ‘Unibet Penalised $1 Million for Gambling Self-Exclusion Breaches’, ACMA (Media Release, 21 May 2025); ‘TAB Penalised $4 Million for Spamming VIP Customers’, ACMA (Media Release, 17 June 2025) <https://www.acma.gov.au/articles/2025-06/tab-penalised-4-million- spamming-vip-customers>. 3 See, eg, Gaming Machines Act 2001 (NSW) pt 4. 4 Here and all other references You Win Some, You Lose More: Online Gambling and Its Impacts on Those Experiencing Gambling Harm (Re- port, Standing Committee on Social Policy and Legal Affairs, June 2023) iii, 1
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