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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.

“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.

The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.

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“The big change is that technology can increasingly provide the infrastructure,” he says. “The creator provides the idea. And I think that will make the industry much more interesting.”

For Yggdrasil, Game in a Box and Studio in a Box are therefore intended to become more than tools for its own development operation. Curwen envisages them supporting a wider creator ecosystem, although he acknowledges that proving the model commercially must come first.

“We’re still early,” he says. “The priority is to prove the model properly; make sure the games perform and demonstrate that it works commercially. If we do that, I think the opportunity is significant.”

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The Malta Gaming Authority (MGA), working alongside the Malta Digital Innovation Authority (MDIA), drafted the voluntary charter following extensive surveys and interviews with industry licensees.

That study found that AI adoption across the gambling industry remained uneven. It highlighted customer support, data analytics, fraud detection, and responsible gaming as areas where the technology was already being heavily used.

However, it also found that formal governance of AI was struggling to keep pace with its growing usage. Only a minority of organizations surveyed reported having a formal AI strategy or roadmap. Many said one remained in development.