In the last year, it has become increasingly clear that supplier oversight is no longer a back-office compliance function. It is a boardroom issue. Regulatory bodies in the UK, North America and beyond have signalled with substantial fines that operators can no longer claim ignorance when third-party failures come to light. The onus is now firmly on the operator to know, monitor and manage its supply chain proactively.
This shift is understandable. In a sector where much of the service delivery and customer interaction is outsourced, the integrity of an operator’s offering is only as strong as its weakest supplier. Whether the risk lies in customer onboarding, payment processing, marketing affiliates or platform technology, regulators expect operators to demonstrate full control. The previous assumption that due diligence at onboarding and occasional audits were sufficient no longer holds.
The message from regulators is stark: if a supplier breaches rules, the licence holder will be held responsible. No matter how complex the supply chain or how distant the third party might seem, there is no safe harbour in pleading lack of knowledge or influence. Boards must now treat supplier management as a core risk comparable to AML, safer gambling, and data protection obligations.
For many boards, this requires a fundamental rethink. Supply chain risk cannot remain siloed within legal or procurement functions. It must be integrated into the organisation’s broader governance framework, with clear reporting lines to senior executives and, critically, to the board itself. Directors must assure themselves that supplier oversight is rigorous, continuous, and tested. It is no longer sufficient to assume that signing a contract with strong terms or relying on supplier self-certification is enough.
Embedding this level of oversight demands investment: in people, in technology, and in culture. Organisations must have the expertise to understand the operational realities of their suppliers, not just their contractual obligations. They need systems that provide real-time visibility into supplier performance and risk. Perhaps most importantly, they must foster a culture where supplier management is viewed not as an administrative burden but as an essential defence of the business’s licence and reputation.
Some may argue that this expectation is disproportionate, especially when dealing with large, sophisticated suppliers who are themselves regulated. Yet recent enforcement actions show that regulators expect operators to apply scrutiny regardless of a supplier’s size or status. If anything, the larger and more complex the supplier, the greater the need for diligent oversight.
Ultimately, the elevation of supplier risk to the board agenda reflects the maturing expectations of gambling regulation. It demands that operators act as true stewards of the end-to-end player experience, even where third parties are involved. Boards who recognise this trend and adapt their governance accordingly will not only mitigate regulatory risk but also build more resilient, trustworthy businesses for the future.
