
Protecting children from illegal gambling sites infiltrating Roblox
Bob Waller, consultant at law firm Spencer West LLP, on the challenges facing regulators and tech firms to quell unlicensed sites targeting minors

Illegal online gambling sites have become an increasingly significant concern in recent years. These illicit operations are primarily created by criminals with the sole aim of profiting from unsuspecting individuals.
Their main objective is to extract money from users without any moral consideration for those they exploit for financial gain, targeting vulnerable players such as compulsive gamblers with an addiction, who find it difficult to control their behaviour and minors who may not fully comprehend the consequences of their actions.
With the avoidance of oversight and regulation, these illegal sites engage in unscrupulous practices, such as refusing to pay out winnings citing unfair and unlawful terms and conditions. The absence of regulation providing recourse to these actions and a total lack of customer protection leaves players on these sites at significant risk. It also means these illegal gambling sites pay no regulatory fees or taxes on their income, maximising their illicit gains.
The recent news of the exploitation of Roblox players is a significant step taken by some illegal gambling operators. Roblox has millions of active users, many of whom are minors. Criminals have figured out how to take advantage of the platform’s in-game currency, Robux, and use it in external gambling sites. The illegal gambling sites that are leveraging the popularity of the Roblox game can do so due to the ease in which the in-game currency is transferrable to their gambling sites using the Roblox user and their ultimate customer’s Roblox log-in data. The casino games provided will generally have an appeal to younger people who may not even be aware they are gambling for real, as they may consider what they are doing is contained within the Roblox platform or is sanctioned by it, leading to a belief that they are merely playing a game within the Roblox game. The concept of “games within games” is not uncommon in many ‘massively multiplayer online games’, further complicating the issue.
This is where Roblox, as the operator of the platform, may be considered partially at fault for the activity of illegal gambling operations, as it appears the company has been slow to act on the growing threat of illegal gambling sites targeting its users. Questions remain over whether it could have acted sooner to try to close down these illegal gambling sites. By not implementing stronger safeguards to prevent the transfer of Robux to external gambling platforms, Roblox may have failed to fully protect its users from exploitation.
Additionally, Roblox has yet to introduce code that restricts or monitors the movement of in-game currency outside the platform unless in accordance with its terms and conditions. Roblox has a duty of care to its users, particularly the younger audience that makes up the majority of its player base. These issues raise questions about the platform’s commitment to ensuring that players, especially minors, are not exposed to risks associated with gambling.
Risky business
The issue of in-game purchasing, including the buying of items such as loot boxes and in-game currency, has raised alarms among gambling regulators around the world. Regulatory bodies like the Gambling Commission have highlighted that these purchases are high-risk activities that may facilitate illegal actions, including money laundering and unregulated gambling.
The challenges faced by regulators in tackling illegal gambling are compounded by the complex tactics employed by criminals to conceal their operations. The individuals behind these illegal sites often hide their identities through the use of Private Domain Registration or Domain Name Privacy Protection services.
These services, often offered by less scrupulous domain providers, conceal the details of the website owner and redirect WHOIS queries to a proxy server. By hiding their identity in this manner, criminals are able to operate with a sense of impunity, knowing that their actions are difficult to trace back to them.
This deliberate obfuscation of their identity presents a major challenge for regulators and authorities attempting to hold these individuals accountable for their actions. It also allows the illegal gambling industry to continue flourishing without significant oversight or intervention.
While illegal gambling is nothing new, it is evolving with the emergence of new technologies and widening the net of its users daily. Regulators and tech firms alike have a significant job on their hands to quell this rise.

Bob Waller, consultant at law firm Spencer West LLP, has 26 years’ experience as a front-line police officer, mostly in CID, working on major crime.
Vetted to DV level for intelligence work, he has spent two years self-employed as a PI conducting investigations for businesses including the SIA and has 18 years’ experience in online fraud investigation and mitigation through system development and design as well as 16 years’ experience in AML-CTF as an MLRO.