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Gambling ads are currently monitored by ASA under the CAP 16.1 code. Just this week, Midnite received its third ASA ruling. The operator was told to remove a TikTok advertisement that featured a young-looking character.
The report singled out several marketing tactics which had been flagged as particuarly concerning.
The first was direct marketing (emails, texts, push notifications). Citing randomised studies, the committee noted that limiting direct marketing resulted in reduced betting and fewer short-term harms.
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Midnite confirmed it had terminated its contract with Limay and would reinforce compliance reminders to its partners.
Limay Media acknowledged that the person depicted was an AI-generated fictional character rather than a real individual and claimed the design was intended to appear as an adult.
The company admitted to lapses in its internal approval process, described the error as isolated and noted the ad was removed within a few hours.
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This required operators to subject players to rigorous checks before signing up new VIPs, including having their betting behaviour being closely monitored.
Operators were also banned from incentivising customers based on losses, and reward programmes must be overseen by senior management. The code restricts any player under the age of 25 from taking part.
According to a GC report from 2025, the number of VIP customers in the market had dropped by 95% per operator since the strengthening of restrictions.