Elena Sadovskaya: Gray Zones Are Closing — Licensing and Compliance Will Decide iGaming’s Future
Elena Sadovskaya, Partner at Inteliumlaw, believes the era of easy shortcuts in iGaming is over. Gray-zone models once seen as loopholes are now under direct regulatory scrutiny, new licensing hubs are reshaping the map, and compliance is no longer a burden but the foundation of long-term growth. In this interview, she traces where the industry is heading—and how operators can stay ahead.
How do you see the regulatory environment for iGaming evolving globally in the next few years, and which markets do you consider the most operator-friendly?
Elena Sadovskaya: Over the next few years, I believe the global iGaming regulatory landscape will develop in three main directions:
1. Regulation of “gray-zone” models
Regulators are likely to put greater attention on business models that have traditionally fallen into a legal “gray area,” such as social casinos, loot boxes, and sweepstakes. These concepts blur the lines between gaming and gambling, with regulators already starting to react.
In the United States, for instance, sweepstakes models have gained massive popularity in recent years. At the same time, however, we’ve seen states issue cease-and-desist letters to sweepstakes and start restructuring laws to either prohibit or regulate such activities.
Europe is likewise moving toward gray area model bans. The UK Gambling Commission consistently highlights the risks of blurred boundaries between gaming and gambling, while Ireland actively debated the loot box model during the adoption of the 2024 Gambling Regulation Act.
This shows operators can no longer rely on “gambling-free” labels, with proper legal structuring and risk management becoming key.
2. Emergence of new licensing regimes
The industry is still adjusting to Curaçao’s regulatory overhaul, while we already witness new jurisdictions entering the stage with the aim of becoming viable alternatives.
Nevis and Timor-Leste, for instance, have launched their own licensing frameworks and entered the market in 2025. On the other hand, multiple countries are introducing national licenses – including Brazil, the UAE, and New Zealand.
This trend is still in its early stages, with more offshore and domestic regimes expected to emerge since governments started recognizing both the tax potential and the broader benefits of regulating the iGaming industry.
3. Stronger compliance and operational requirements
Across jurisdictions, we also see a clear trend toward tightening AML/KYC requirements, responsible gambling measures, and technical standards for platforms. Regulators are demanding not just financial compliance but also sufficient player protection, transparency, and technology integrity.
For operators, this means higher entry barriers but also greater opportunities to build sustainable, reputable businesses.
Speaking of “operator-friendly” markets, it’s difficult to identify such, given that there is no cross-border recognition of gambling licenses. Each jurisdiction protects its own licensing regime. In practice, operators often find the most flexibility either in an unregulated or lightly regulated environment; jurisdictions offering relevant local licenses are also a great option.
Inteliumlaw advises clients in multiple jurisdictions. Which regions or countries do you see as the most promising for online casino operators in 2025, and why?
Elena Sadovskaya: I would highlight the Asia-Pacific region as the fastest-growing market. Over the past four years, it has recorded around 68% growth, and projections suggest it could double again in the next decade. The rapid population growth, rising digital penetration, and strong demand for mobile-first entertainment make it the most dynamic iGaming market globally.
Another promising region is LAMEA (Latin America, the Middle East, and Africa), which is expected to grow 27% annually over the next eight years. Latin America is experiencing great momentum, with countries like Brazil introducing new regulatory frameworks that will create structured opportunities for licensed operators, while Africa is seeing rapid expansion driven by mobile gaming adoption.
Among emerging opportunities, the UAE is worth attention. With the recent establishment of a federal authority for commercial gaming and discussions surrounding regulated casino resorts, the UAE is positioning itself as a new, highly promising iGaming market.
What are the most common mistakes you see companies making during the licensing process, and what strategies can help operators avoid these challenges?
Elena Sadovskaya: One of the most common mistakes companies fall for is choosing the wrong jurisdiction for incorporation. Many startups assume they can operate with any company without properly considering important aspects such as licensing costs, taxation, banking access, and long-term compliance. This often creates unnecessary risks and subsequent costs.
The second most frequent issue is selecting an unsuitable license. I’ve seen many cases where business owners opt for a license that does not match their actual business needs or fails to meet their operational expectations – typically because they did not seek proper legal advice early in the process.
Timing is also crucial. A large part of companies start the licensing process too late, often at the point when they already need to be operational. Yet streamlined licensing is never guaranteed; regulators rarely meet deadlines, with weeks of delays being common in the industry. Robust planning and realistic timelines are essential for a disruption-free business launch.
Finally, a major pitfall is trying to navigate the process without professional expertise. The regulatory landscape is complex and highly jurisdiction-specific. Without experienced legal and compliance support, operators risk costly mistakes, delays, or even rejections.
The best strategies to avoid these pitfalls are to carefully align the business model with the right jurisdiction and license, start the process well in advance, and involve professionals who understand both the local regulations and the global market context.
How are recent legal frameworks balancing the need for responsible gaming measures with the operational flexibility that online casinos require?
Elena Sadovskaya: Recent regulations are putting more emphasis on responsible gaming, but in a way that doesn’t make operations impossible for casinos. The balance is achieved with regulators encouraging the use of automation and technology; most frameworks now require built-in tools such as cooling-off periods, self-exclusion, deposit limits, and access to recognized self-assessment tests like the Gamblers Anonymous 20-Question Test.
At the same time, many regulators expect operators to use automated KYC checks and strict age verification to block under-18 players. These measures protect consumers and give operators clear, practical standards instead of leaving them with vague obligations.
As a result, the iGaming industry introduces stricter responsible gambling oversight while also allowing businesses to stay flexible and scale.
With the growing popularity of cryptocurrency in iGaming, what legal considerations should operators keep in mind before integrating crypto payments?
Elena Sadovskaya: There is a common misconception that operating in crypto eliminates the need for companies to hold a gambling license. In reality, gambling regulation applies regardless of whether payments are made in fiat or cryptocurrency. Since certain regulators still do not accept operators that want to run purely as “crypto casinos,” addressing this during business structuring is a must for future operators.
Not only that, but keep in mind that most reputable crypto payment processors will only work with licensed operators. Without a proper license, partnering with reliable payment providers can be close to impossible.Finally, iGaming companies need to consider the fact that crypto transactions carry a higher risk of money laundering.
To combat this, regulators expect businesses to apply enhanced AML and KYC procedures, with strong monitoring of player activity and onboarding checks. This means crypto can be an opportunity to attract new players, but only if it goes together with the right compliance framework and licensing strategy.
From your experience, what types of legal disputes are most common in the iGaming industry, and how can companies proactively prevent them?
Elena Sadovskaya: Regulatory disputes are by far the most common in the iGaming sector. According to recent reports, the global casino industry incurred over $160 million in regulatory fines and penalties in just the first half of 2025.Based on our overview, the majority of these penalties arise from AML/KYC compliance failures, followed by cases of illegal gambling operations, breaches of responsible gambling obligations, and mixed regulatory violations. A recent example is Curaçao’s first major KYC enforcement action from July 2025, where 12 operators were sanctioned for systematically failing to follow proper identity verification procedures.
To proactively prevent such disputes, operators should focus on 3 things:
1. Robust compliance systems: embedding strong AML/KYC controls into everyday operations, instead of treating them as a formality.
2. Early legal structuring: ensuring that the chosen license and jurisdiction perfectly align with the business model from the very beginning to avoid future enforcement for operating outside of the permitted scope.
3. Continuous monitoring and audits: keeping up with evolving regulations and demonstrating full compliance beyond what is achieved at the application stage.
In a nutshell, most disputes can be avoided if operators treat compliance as a core business function rather than a box-ticking exercise.
What challenges do operators face when dealing with international taxation and cross-border compliance, and how does your firm assist in these areas?
Elena Sadovskaya: Navigating conflicts between global and local regulations, particularly when it comes to taxation and cross-border compliance, is one of the biggest challenges operators face in iGaming today. Each jurisdiction has its own tax rules, licensing requirements, and reporting requirements, which often overlap or, in some cases, contradict each other.
At Inteliumlaw, we have a well-developed iGaming consultancy practice, advising clients on international business optimization and structuring. Backed by a Big 4 background in tax consultancy and cross-border structuring, our team brings practical, compliant solutions that best suit unique business needs. This helps clients avoid double taxation, reduce regulatory risks, and build business structures that are sustainable in the long term.
How is technology – such as automation or AI – helping iGaming businesses stay compliant more efficiently? Do you see it becoming a requirement rather than an option?
Elena Sadovskaya: While automation and AI have not yet become a universally applicable regulatory requirement, it is highly unreasonable for operators to ignore these tools today. They are indispensable when it comes to reducing human error and meeting compliance obligations more efficiently – whether automating KYC, monitoring transactions for AML risks, or flagging responsible gaming concerns.
At the same time, we already see certain technology-driven concepts becoming mandatory. Under the new eIDAS 2.0 framework (Regulation (EU) 2024/1183), for instance, the EU is moving toward requiring iGaming operators to integrate Digital Identity Wallets for player authentication.
That said, regulators are approaching the future with technology being a compliance standard rather than a competitive advantage. While most tools are optional today, technology-enabled compliance is expected to become a new norm for the iGaming industry.
What advice would you give to new or expanding iGaming operators who want to future-proof their business against regulatory changes?
Elena Sadovskaya: First, never underestimate the importance of licensing. Many startups still assume operating from unregulated jurisdictions is a shortcut; in reality, this creates long-term risks with regulators, payment, and software providers.
Second, operators should carefully analyze their business model to structure it properly, especially when entering so-called “gray zone” areas like loot boxes or sweepstakes. These models are under increasing scrutiny, and improper structuring can quickly lead to regulatory challenges.
Third, it’s crucial to implement strong KYC procedures and responsible gambling tools from the very beginning. These are no longer optional, as players and regulators expect operators to have them in place, with the latter imposing substantial penalties for the lack of such.
Finally, operators should study the regulations of their target markets thoroughly and work with qualified legal experts who understand both local frameworks and international trends. Having the right guidance at every stage helps mitigate risks and build a business that can turn ever-changing legislation into a competitive advantage.
In summary, solid licensing, proper structuring, strong compliance, and expert advice are the best ways to future-proof an iGaming business.
What role does Inteliumlaw aim to play in shaping the future of legal compliance within the iGaming industry over the next five years?
Elena Sadovskaya: At Inteliumlaw, we already help clients set up in the world’s key gambling jurisdictions – including Malta, Estonia, Isle of Man, Curaçao, Nevis, Tobique, Kahnawake, Costa Rica, and Anjouan – and we continue to expand our portfolio.At the same time, our mission goes well beyond helping clients obtain licenses.
Our team acts as long-term legal and compliance partners, guiding iGaming businesses of different kinds through every stage of their growth.
Looking ahead, our focus over the next five years will be assisting businesses to anticipate and adapt to shifting regulations in key gambling markets. This means not only ensuring day-to-day compliance but also building tailored, forward-looking strategies that allow our clients to adapt quickly and remain competitive.
Inteliumlaw will also continue developing expertise in emerging regimes, such as the UAE, where our firm is uniquely positioned to support businesses on-site.
Our team is genuinely invested in each client’s success. Therefore, our main goal is to offer solutions that help clients stay both compliant and competitive by anticipating regulatory changes and building resilient, efficient, and future-proof structures.