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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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The Authority said licensed operators accepted P150 million in wagers in March 2025, paid P135 million in winnings and generated P15 million in gross gambling revenue. It also estimated that only about 40% of Botswana’s estimated 550,000 active bettors were using licensed local operators, leaving a substantial share of demand with unregulated platforms.
By December 2025, Kemorwale said gambling revenue had exceeded P700m, and the Authority expected the industry to surpass P1 billion by the end of the 2026/27 financial year in March 2027.
Kemorwale said Botswana needed to modernise oversight as the sector developed, including through a central electronic monitoring system and stronger enforcement capability. “Truth be told, this industry is evolving as the sun rises. You snooze, you lose,” Kemorwale said. He added that the Authority still relies on outside specialists for some technical regulatory work because domestic expertise is limited.
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The company also highlighted its own research that suggests over 80% of consumers cannot “confidently distinguish” licensed operators from unlicensed ones.
Stella David, Entain’s CEO, called for the government to move ahead with the ban immediately, arguing clubs were already aware of the planned changes.
“Premier League clubs that have struck new deals with unlicensed gambling operators knew the risks,” she said. “The government made clear in February that it would bring in a ban and it should do so immediately: even if that means clubs ordering new kit mid-season.