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Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds. 

Giles Thomson, FATF president, said unregulated sectors risk becoming “attractive gateways for fraudsters, professional money launderers and organised criminal networks”. He called on governments to strengthen oversight, crack down on illegal and offshore operators and deepen public-private cooperation. 

The Danish Gambling Authority said on Friday that the report stems from a broader review by FATF member countries over the past year.

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Yaxley adds: “The most meaningful measure of progress is not simply who joins an organisation, but whether opportunities, development and leadership pathways are accessible to everyone.”

Despite the progress made, interviewees agree there are still areas where the gambling industry has work to do.

“I believe there is still work to be done to ensure diversity is fully reflected at every level of an organisation, particularly within senior leadership and executive positions,” Yaxley says.

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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.