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That distinction also informs his view of the wider battle. Asked whether illegal gambling can actually be defeated, his answer is: “No, but you can make it very difficult for them.”

The objective, he argues, is to make it harder for operators to simply replace a blocked domain with another one. “If they knew there was a tool that would find those new sites as well, they might become more cautious.”

It is a philosophy that sits within a broader shift in the industry’s approach to the illegal market. Domain blocking remains important, but regulators are increasingly looking at payments, advertising, affiliate and acquisition channels and cooperation across jurisdictions.

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Her previous leadership roles include chairing the Independent Parliamentary Standards Authority (IPSA), the Bar Standards Board and acting as a lay member of the General Medical Council. 

Evans also served as a non-executive director of the Serious Fraud Office. She led the steering group responsible for a voluntary industry code that reimburses victims of authorised push payment (APP) scams, introduced in 2018.

Ahead of his departure Counsell said the Commission was developing a new strategy and ramping up its work to tackle illegal gambling, with Evans set to play a “pivotal” role as it also finalises measures from the Gambling Act review’s subsequent white paper.

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There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.

“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.