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Abstract
This article presents the results of a comprehensive analysis of international regulatory models governing the gambling industry and preventing gambling addiction, based on the examples of the United States, the United Kingdom, France, Sweden, and Lithuania. Using a comparative framework, the study examines legal instruments, fiscal mechanisms, self-exclusion systems, advertising restrictions, age limits, measures for protecting vulnerable groups, and digital monitoring tools. The findings reveal a clear evolution of policy approaches—from predominantly prohibitive frameworks toward risk-oriented and socially responsible regulatory models.
Special attention is devoted to national monitoring systems, the clinical recognition of gambling addiction, prevention and treatment measures, and the regulation of emerging digital gambling formats. The study also incorporates international rankings on public interest in gambling, the number of active players, annual expenditures on gambling, and the prevalence of gambling disorders, enabling an integrated assessment of industry development and associated social risks across countries.
Based on the analysis of foreign experience, six priority directions for adapting international practices in Kazakhstan are proposed: establishing a unified national gambling regulator, implementing a robust self-exclusion system, modernizing the tax regime through a “place-of-consumption” principle, strengthening international cooperation against illegal online operators, advancing “responsible gambling” initiatives, and developing a highly controlled online gambling segment.
Overall, the findings demonstrate that effective governance of the gambling sector requires a balanced combination of economic incentives, digital oversight tools, coordinated inter-agency efforts, and strong public-health-oriented measures aimed at protecting the population from gambling-related harm.