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Yet Dan Waugh, partner at Regulus Partners, pushes back against the idea that enforcement notices reveal a fundamentally non-compliant sector.

“Operators failing compliance checks is never a good look,” he says. Campaigners often claim that financial sanctions are priced in and that the Commission should revoke more licences, although Waugh does not believe operators view settlements merely as a cost of doing business.

Nor are regulatory breaches unique to gambling. Waugh notes that Tesco was fined more than £8 million for food hygiene failings in 2021, without parliamentarians demanding that it should be prevented from selling cornflakes.

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She suggested that the State Revenue chief commissioner’s office would be better equipped to manage what she characterised as a tax rebate programme.

NSW government figures classify poker machines as the most harmful gambling format in the state, yet clubs continue to operate approximately 65,000 poker machines, benefiting substantially from tax rebates through the scheme.

Green MP Cate Faehrmann has criticised the arrangement, highlighting a conflict of interest where clubs reduce their tax liabilities while simultaneously cultivating community goodwill. 

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For free-to-play, that process can begin before the customer has committed money. “It’s about building muscle memory, providing achievable incentives to players and gamification,” Wilson explains. By lowering the barrier to participation, a free-to-play game can provide an accessible first interaction with an operator, while repeated play builds familiarity and creates a reason to return.

The format, however, cannot simply be copied and pasted from one market to the next. “We’ve found that the more localised the offering, the better,” Wilson says. “We’re talking about building anything from sumo wrestling to Love Island, as well as the headline sports. Ice cage fighting has been a popular one in a certain market for us.”

It is an eclectic list, but that’s kind of the point. Relevance can mean a global sporting event in one market and a far more niche (see ice cage fighting) obsession in another. Splash Tech’s job is to find the experience that fits the audience, rather than expecting the audience to fit the product.