Sports betting integrity has moved firmly to the top of the regulatory agenda.
Over recent months, Regulatory Authorities have intensified its supervision of Suspicious Betting Incidents (SBIs) through targeted compliance reviews, desk-based assessments, and thematic audits. These reviews focus on whether licensees have effective, documented, and operationally embedded frameworks capable of identifying, assessing, escalating, and reporting suspicious activity in a timely and defensible manner.
In our experience advising licensees undergoing compliance reviews and audits, sports integrity is increasingly treated as a governance issue rather than a reactive reporting obligation.
This article highlights key areas licensees should assess when reviewing their internal SBI framework. While these points provide a strong foundation, experience shows that fully compliant and regulator-ready SBI practices require tailored implementation and expert regulatory input.
What the Regulator Is Really Assessing
The Regulator’s expectations extend beyond the existence of a written policy, albeit it being highly important.
During integrity reviews, the relevant regulatory authorities typically assesses whether a licensee can demonstrate that it has practical systems and controls in place to effectively detect unusual betting activity, escalate concerns internally, and make informed decisions on reporting obligations. Equal importance is placed on documentation, accountability, and the ability to evidence why particular decisions were taken.
In our experience assisting licensees undergoing audits, regulatory concerns frequently arise not because incidents were missed, but because the operator could not clearly demonstrate how incidents would have been detected, who was responsible for escalation, or why a decision to report or not report was ultimately taken.
Key Areas Operators Should Assess
Defining What Constitutes a Suspicious Betting Incident
A robust SBI framework begins with clarity.
Licensees should ensure that their procedures clearly explain what may constitute suspicious betting behaviour within the context of their specific products and markets. Overly generic and boilerplate definitions and frameworks provide little practical guidance and often fail to meet regulatory expectations.
In our experience, effective procedures strike a balance between regulatory guidance and operator-specific risk based approach, ensuring that staff understand when activity should be treated as potentially suspicious rather than merely unusual, or even be detected at all.
Detection and Monitoring Arrangements
One of the first questions typically raised during reviews is how suspicious betting activity would actually be identified in practice.
Operators are expected to demonstrate that detection mechanisms are proportionate to their business model. For some licensees this may involve automated alerts and integrity monitoring tools, while for others it may rely on structured manual reviews supported by defined thresholds.
What is critical is that detection is not purely reactive. In our experience, frameworks that rely solely on external notifications or customer complaints are frequently viewed as insufficient.
Internal Escalation and Ownership
Clear internal escalation procedures and clear reporting lines are central to effective sports integrity controls.
SBI procedures should specify who is responsible for reviewing alerts, when matters must be escalated (and often forgotten, to whom), and which function holds final authority for reporting decisions. Where multiple departments are involved — such as compliance, risk, trading, or operations — responsibilities and decisions together with their rationale must be clearly documented.
Unclear ownership and fragmented decision-making are among the most common weaknesses identified by regulators, in our experience.
Reporting Obligations and Timelines
Licensees must be able to demonstrate a structured approach to reporting SBIs to their regulator and, where applicable, to relevant Sports Governing Bodies.
Procedures should clearly outline reporting timelines, approval processes, and the information required to support submissions. Internal uncertainty around these steps frequently leads to delays, incomplete reports, or inconsistent regulatory engagement — all of which may increase scrutiny and trigger further reviews and audits.
Documentation and Audit Trails
Regulators increasingly expect licensees to maintain comprehensive records relating to sports integrity matters.
This includes documentation of detected incidents, internal analysis undertaken, communications between teams, reporting decisions, and any submissions made to regulators or sports bodies. The absence of documented reasoning — even where the final outcome was appropriate — is often treated as a compliance gap in its own right.
Staff Awareness and Training
Even the most detailed SBI procedure will be ineffective if it is not understood by relevant staff.
Operators should ensure that employees receive appropriate training tailored to their role and exposure to betting activity. Regulators commonly assess whether staff understand escalation triggers and whether training records can be produced on request.
Ongoing Review and Enhancement
Sports integrity risks evolve continuously.
SBI frameworks should therefore be subject to periodic review, taking into account regulatory guidance, emerging betting risks, internal findings, and lessons learned from reported incidents.
In our experience assisting licensees, outdated or static documentation is one of the most frequent issues identified during regulatory assessments.
A Strong Starting Point — Not a Complete Solution
The areas outlined above represent the core foundations of an effective sports betting integrity framework.
However, in practice, SBI compliance is rarely a box‑ticking exercise. Each framework must be tailored to the operator’s products, customer base, market exposure, technology infrastructure, and organisational structure.
In our experience advising licensees undergoing compliance reviews and audits, the distinction between satisfactory and unsatisfactory outcomes often lies in how well these elements are aligned, documented, and operationalised — rather than whether a policy simply exists.
How CSB Can Assist
While these considerations provide a strong baseline, effective and a regulator‑ready SBI policies, procedures, and practices require expert regulatory insight and practical implementation support.
The CSB Legal and Regulatory team regularly assists licensees with:
Comprehensive SBI policy and procedure reviews
Gap analyses against regulator expectations
Enhancement of detection and escalation frameworks
Early engagement and tailored advisory support significantly reduces regulatory risk and strengthens long‑term compliance.
Final Thoughts
With Regulators actively conducting sports integrity reviews, now is an opportune time for licensees to critically assess whether their SBI framework is genuinely fit for purpose.
The guidance above covers the fundamentals — but effective, defensible, and regulator‑ready sports integrity practices demand more than a standard template.
For a full review of your SBI policies, procedures, and operational practices, we invite you to contact the CSB Legal and Regulatory team.
