Why Gray Market Operators Must Pivot to Regulated Markets | David Carruthers
with David Carruthers, Principal & CEO, David Carruthers Consulting Limited
- Quantum Gaming

- Kensho Media

Credited on the iGaming Real Talk podcast episode. Not advertising on this site.
Prediction markets are everywhere right now.
But are they gambling or something entirely different?
In this episode 59 of iGaming Real Talk, our host Surya Palli meet with David Carruthers, Principal & CEO of David Carruthers Consulting Limited, to talk about leadership, regulation, prediction markets, gray markets, and why the industry needs to do a better job of speaking for itself.
David has seen the industry grow from the very beginning. His views are direct, practical, and shaped by decades of experience across regulated markets around the world.
In this episode, we cover
- Why the iGaming industry deserves more respect
- The biggest mistake operators make with regulators
- Why gray markets are a short-term strategy
- His honest take on prediction markets
- How operators should think about regulation
- Why listening is one of the most important leadership skills
- The problem with modern executive leadership
- The role of gut instinct when building a business
- Advice for young founders entering the industry
Key takeaways
- The biggest opportunity in iGaming isn't the money. It's where the industry can take you. "The opportunity is boundless." David began his career in the betting industry writing race results on a whiteboard before going on to build businesses around the world. Looking back on nearly five decades in the industry, he says the greatest reward wasn't financial success but the opportunities the industry created throughout his life. For him, iGaming rewards people who are willing to grow with it.
- Leadership defines the culture before strategy does. "Leadership sets the scene." David believes the success of any business starts with its leadership. Great leaders create the culture, standards and direction that everyone else follows. According to him, organisations become reflections of the people leading them.
- Learning starts by listening. "The most important thing in creating a learning experience is having the discipline to listen." After decades in business, David believes one habit separates lifelong learners from everyone else. Listening to customers, colleagues and even yourself creates the foundation for continuous improvement. For him, listening isn't passive. It's the starting point of every learning process.
- Regulation works best when it's built through collaboration. "It's all about interaction." David argues that good regulation isn't created through confrontation. The best outcomes come when operators and regulators communicate consistently, share knowledge and work together over time. In his view, progress happens through education and professional dialogue, not conflict.
- Long-term businesses are built through patience. "People need to be more patient and more focused on reaching a sustainable model." David believes many companies sacrifice long-term success for immediate results. Businesses should invest in understanding customers, building sustainable models and creating lasting value. Patience, he says, is often a competitive advantage.
- Integrity is worth more than short-term profit. "Stop looking at your business model and pivot to the regulated market." Speaking about grey markets, David encourages businesses to focus on regulated markets, even when growth appears slower. He believes companies with strong products and genuine expertise will succeed without relying on shortcuts. Long-term trust creates stronger businesses than short-term opportunity.
- Technology is only valuable when it helps you understand customers better. "Every customer has value, but they only have value if you treat them in the appropriate way. And you can only do that if you have the right information." David believes data and technology should be used to better understand customer behaviour rather than simply increase profits. The more businesses understand individual players, the better they can personalise experiences while encouraging responsible gambling. Customer understanding, not technology itself, creates value.
- Discipline beats motivation in business. "Before I go to sleep every night, I update the to-do list." Sounds simple but this is David's most practical lesson is the importance of personal discipline. Whether running businesses or serving time in prison, he maintained the habit of prioritising daily tasks and managing his time deliberately. For him, consistent routines create long-term success.
- Your biggest business decisions should come from conviction. "Do you believe in this? Are you prepared to lay yourself on the line?" While research and analysis matter, David believes the final decision often comes down to personal conviction. Building a business requires committing fully to an idea and believing in it even when outcomes are uncertain. Success begins when conviction is stronger than doubt.
Notable quotes
The most important thing in creating a learning experience is having the discipline to listen.
People need to be more patient and more focused on reaching a sustainable model.
Every customer has value, but they only have value if you treat them in the appropriate way.
About the guest

David Carruthers
Principal & CEO, David Carruthers Consulting Limited
David Carruthers is the Principal and CEO of David Carruthers Consulting Limited. With decades of experience witnessing the growth of the iGaming industry from its inception, he is a seasoned expert in global regulated markets and executive leadership.
LinkedIn profileTranscript excerpt
A short passage published by the podcast, not the whole conversation.
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- Surya Palli
Barcelona, Dubai, San Paulo, Madrid, and now we here in Manila. And we spoke to leaders, experts, as well as industry pioneers talking about what's happening in Asia, what's also happening with the Filipino gaming market, and the wider Asian region. This series is brought to you by Kensho Media. They have been helping iGaming companies rank higher with SEO since 2008. This series is also brought to you by Quantum Gaming.
They help companies with white label and turnkey solutions in emerging markets. This year we're doing with real roadshow initiative as part of iGaming real talk where we go to iGaming events all around the world and cover the insights from the ground. Stay tuned and subscribe to iGaming real talk. Hello and welcome back to another episode of iGaming real talk.
I'm here with David at Sigma Asia in Manila, and I'm very excited to get into some of the things that I always wanted to ask him. So, David, welcome to the show.
- David
Thank you.
- Surya Palli
It's great to always come back to Sigma because the energy is just different, and there's more people than ever all the time. Don't you think so?
- David
Well, I mean Sigma's an iconic brand in the event circuit.
- Surya Palli
Yeah.
- David
It's always been professional. It's always been entrepreneurial as well and expanding into new areas and this is an example of a new area...
- Surya Palli
Yeah.
- David
Doing the podcast live from the floor of an event like Sigma.
- Surya Palli
Yeah, absolutely. I mean, I worked at Sigma so I may be biased but I always love coming back to Sigma because of the energy. I go to other events as well. All events are great. I think they have their own little thing but Sigma has a little bit more in terms of like the energy. That's what I feel.
- David
Well, it has the DNA of Eman so maybe that's where the energy comes from. You know, I'm a great believer in the importance of leadership. Well, you mentioned before we had gone live talking to Alex from Alea. There is a gentleman that lives and walks his talk as a leader. Eman Pulis is another gentleman that lives and walks his talk as a leader. And no disrespect to the operational management in Sigma would do a tremendous job.
- Surya Palli
Yeah.
- David
You know, leadership sets the scene and that's why this place is one different and two successful.
- Surya Palli
And I attribute a lot of things in my career as well as where I am today is also because of my experience at Sigma and I carry all the things that I have learned from Eman and working at Sigma in this journey because it's nothing like anything else. It's like stress testing yourself to the real world out there, you know.
- David
Well, life is not a rehearsal. It's life. So, you can only take out what you put in and the most important thing understood and become in love with is the most important thing in creating a learning experience is having the discipline to listen. You have to listen. Sometimes you have to listen to yourself. Sometimes you have to listen to others. Sometimes you have to listen to a group but listening is the first point in a learning process.
- Surya Palli
That's why you think we have two ears and a mouth?
- David
Uh, maybe. I never thought about it like that.
- Surya Palli
[laughter] Like we have to listen twice...
- David
Twice as much as you talk. Uh, that's interesting observation and it might be a good best practice.
- Surya Palli
Yeah, yeah. We try. We try but you know, you've had one of the amazing journeys in the iGaming space itself in the very beginning with Ladbrokes as well as building your own company, taking it public, and then the aftermath which we all know. So, what I want to ask really ask you is what are your two biggest takeaways from this 50 years of experience? Someone watching, they're thinking should I go into iGaming business? Should I just make a lot of money because it's iGaming?
What would you say to them? Like what's your biggest takeaways from your journey?
- David
Well, my journey is what's always inspired me is the opportunity. The opportunity is boundless. We said 50 years. I started in April 1976. And my first job was the lowest job in the ecosystem there is. I used to write the words on the whiteboard about who won the race, who was second, who was third. And I've done everything in between. And it's been a euphoric journey. It's not always step-by-step. Some was there but then a big step and then a big step or whatever.
But it gave me opportunity I never dreamt of. I've been all over the world. I speak Mandarin. I would never have done that without this industry. The thing that frustrates me about this industry is that sometimes I think the leadership in this industry do not demand the respect they deserve from the wider business community because it's gambling.
- Surya Palli
Yeah, there's a stigma attached to it.
- David
Exactly. And it's ridiculous. Look at the number of people we employ. Look at the technology we generate. Look at the number of customers that we entertain and keep happy. Look how we are pivoting and learning and installing and implementing protection systems that will exist the longevity of this business, acting responsibly. That's because of this business.
- Surya Palli
What do you think needs to change? Is it mainly because of the regulators? Is it mainly because of the politicians? Where is this coming from? I mean, the stigma especially.
- David
Everybody has to change. Everybody has to learn. Everybody has their weaknesses and everybody has their strength. Now, you can look at regulators and I will not select one particular regulator.
- Surya Palli
Yeah.
- David
But, their biggest deficiency is understanding the commercial reality of this industry and the customer behavior.
- Surya Palli
Yeah.
- David
And understanding and embracing and recognizing that if they are too strict, then they just increase the bad behavior. It's a little bit like bringing up a child.
- Surya Palli
Yeah.
- David
You have to show discipline, but if you only show discipline and no love, you get bad behavior.
- Surya Palli
Yeah.
- David
It's similar.
- Surya Palli
Cuz they do the opposite then, you know.
- David
Yeah. It's market dynamics as well.
- Surya Palli
Yeah.
- David
You will never eradicate everything that is bad. You will never create everything perfect. That's also a recognition that you need to have. But, as long as you're responsible and you are keeping up to pace with technological innovation, even things that are happening, analyzing the current and the past to make sure the future is stronger, then you're acting responsibly and you're doing a good thing.
One of the things that have always been, maybe in the last 20 years, has been less than satisfactory for me, is that I think people at the C-level in this industry have been rewarded too high.
- Surya Palli
Are?
- David
Been rewarded too high.
- Surya Palli
Oh, that's true.
- David
Too many bonuses and incentives that have skewed their behavior to a personal goal rather than an industrial goal. I can say that. I've been here 50 years, you know. It's different.
- Surya Palli
Yeah. But, do you think there's a way out? There's a way to change now?
- David
Well, I mean, it's about education.
- Surya Palli
Yeah.
- David
It's about education, you know. I mean, we talked about Alex. Alex doesn't talk about a team.
- Surya Palli
No.
- David
He talks about a tribe.
- Surya Palli
Yes.
- David
You're part of his tribe. Now, that's a bit cavalier thing, but he's the greatest team leader I've seen in this industry recently, cuz he walks his talk. He does what he says he's going to do. Doesn't say, "You do it like this." and then, when you're not looking, I will do it like that. He doesn't do that. But others do.
- Surya Palli
Yeah, a big admirer of Alex, very much in touch. Which also brings me to one of the things that you mentioned on Under Pressure Podcast very recently. You mentioned something like, you know, industry has a habit of giving more importance to short-term profits than the long-term. So, could you like expand on that a little bit more and tell us like what needs to be done?
- David
First of all, people need to be more patient and more focused on reaching a sustainable model. We were talking about I was on main stage earlier today. And we were talking about the dynamics of bringing omni-channel together. So, land-based and online. You know, one of the success stories on this is that it's forcing businesses to really begin to try and understand the customer and the customer behavior.
- Surya Palli
Yes. And...
- David
I said when I tried to make the point that it's not about love all your customers or high value customers. Every customer has value, but they only have value if you treat them in the appropriate way.
- Surya Palli
Yes.
- David
Treat them in the appropriate way if you have the information.
- Surya Palli
Yes.
- David
So, if you have that information on their behavior, then you can guide them from doing bad things.
- Surya Palli
What is relevant for them more?
- David
Exactly. I but you can also give them opportunity to expand their experience or complement their experience. Whatever. But that take time, effort, energy, and focus. And we're just beginning that journey. New technologies, new big data analytics that are available...
- Surya Palli
Yeah.
- David
Are giving us the tools. But if you abuse these tools, the short-term...
- Surya Palli
That's a very good point. And even when it comes to regulation in general, you've seen the industry from very long time. Do you think some of the mistakes are being repeated? For example, if you look at UK...
- David
Absolutely.
- Surya Palli
Brazil...
- David
Absolutely.
- Surya Palli
Do you think Asia is repeating the same?
- David
But wait a minute. It's not just online.
- Surya Palli
Yeah.
- David
Or before online, regulation was also stupid.
- Surya Palli
Same.
- David
Well, it was the same. It was different, but it was also stupid. It was never perfect.
- Surya Palli
Yeah.
- David
But it adjusted. It adjusted through proper, professional interaction between the operators...
- Surya Palli
Yeah.
- David
And the regulator. So, how did we get TV in the betting shops?
- Surya Palli
Yes.
- David
How did we get the betting shops open 7 days a week?
- Surya Palli
Yes.
- David
How did we get to put a slot machine in the corner of the betting shop? Interaction with the regulator. Economic... was it tough?
- Surya Palli
All the time?
- David
Of course it was tough. The people that did it were good at it. Then we had to go online and then we got a different view and a different context. And maybe some of the people that were good have moved on and have retired and their replacements weren't as strong.
- Surya Palli
Yeah.
- David
It's all about interaction.
- Surya Palli
Yeah.
- David
You know, the regulator is not a fool. He understands or she understands.
- Surya Palli
Mhm.
- David
But without communication, without interaction that is proper and professional and structured and over a long period of time. You're not going to do everything in 5 minutes.
- Surya Palli
Yeah.
- David
You have to be patient, consistent.
- Surya Palli
Yeah. You know, one of the other things also that you mentioned in under pressure podcast is that losing the integrity hurt you more than actual time in the prison itself. So, based on that, we see a lot of operations, operators pushing very aggressively in gray markets at the moment. What advice do you have for them?
- David
Stop looking at your business model and pivot to the regulated market. Because if you've got a product and a capability and an understanding of this industry, you will be successful.
- Surya Palli
I think there's a misconception really that regulated markets don't get us enough.
- David
No. Gray market operators as they call themselves are trying to take a shortcut to profitability. They're trying to use a USP that's not available to the regulated person because the regulated person is paying all the taxes and the blah blah blah, okay? They have an unfair advantage that they should not be given. Yeah. So, that's up to society. It's up to the customer to recognize.
It's up to the industry to educate the customer who the bad guys are and why they're bad guys and why we're good guys.
- Surya Palli
Yeah, but do you think they are doing that job correctly?
- David
I don't know specifically.
- Surya Palli
Yeah, for example, if you look at the UK, I mean...
- David
I don't underestimate the size of that job.
- Surya Palli
Yeah.
- David
But, I think that it's a job that they must do.
- Surya Palli
Yeah. Yeah. For example, in the UK, according to the recent changes, I mean, it's very difficult to follow everything and stay profitable. That's what the operators are saying.
- David
That's an economic fact. That there are some efficiencies that they can install and efficiencies that will help.
- Surya Palli
Yeah.
- David
But, you know, if I was a CEO of a UK-facing...
- Surya Palli
Yes.
- David
Omnichannel business, I'd be on the doorstep of the UK Gambling Commission one day a week, all day, every day. I'd be sharing data, sharing information, educating people. I'd be hiring professional people to lobby. I'd be using that initiative as a branding tool for my business. I'd be getting customer respect because of what I'm doing, cuz I'm doing the right thing for you. I mean, that's what got me into trouble in the first place, by the way.
- Surya Palli
Yeah.
- David
United States, because I was successful in doing that. And what happened in the United States is what I expected would happen.
- Surya Palli
Yeah.
- David
But, it didn't happen for 10 years.
- Surya Palli
So, you essentially fast-tracked it.
- David
Well, I think I stimulated it, and I was right. I was just too early.
- Surya Palli
Yeah, now the market is exploding.
- David
Good. The market is actually maturing.
- Surya Palli
Yeah.
- David
The market is expanding because the product range is expanding and developing. And that's through technological innovation.
- Surya Palli
Yeah, what do you think about the prediction markets, which is the talk of the year?
- David
Gambling.
- Surya Palli
It is g- Well, I mean, if we look at Kalshi...
- David
Yeah.
- Surya Palli
90% of the bets on Kalshi are sports contracts, more than 90%, sometimes.
- David
It's gambling. Full stop. There will never be anything other than gambling.
- Surya Palli
Do you think...
- David
Call it what they like. You know, they will regulate it how they see fit.
- Surya Palli
Yeah.
- David
But, it's gambling.
- Surya Palli
They branded it well. I mean...
- David
Well, they didn't do anything. All they did is take a concept that was widely known before...
- Surya Palli
Yeah.
- David
And they put it to market. And they put it to a market in a market that is synonymous with trading...
- Surya Palli
Yeah.
- David
On the stock exchange because their pension fund is run through something called a 401K. So, everybody is participating or nearly everybody is participating in the stock exchange. And the stock exchange is up here.
- Surya Palli
Yeah.
- David
And the betting shop in Vegas is down here.
- Surya Palli
Here.
- David
You know? And that's the reality. So, it, they saw an opportunity and they used that up here high-end marketing tool.
- Surya Palli
Yeah.
- David
Asked me the question is it gambling or what is it? It's gambling.
- Surya Palli
Yes. It's actually very genius and smart in a way because they're targeting the crypto guys. They're targeting the operators on gambling. They're targeting trading and binary ops. They've made...
- David
All they've done is something.
- Surya Palli
All they've done is expanded the potential customer.
- David
Yeah.
- Surya Palli
Now, remember I used to run betting shops.
- David
Yeah.
- Surya Palli
I know the traders on the stock exchange bet in betting shops.
- David
Profile is the same.
- Surya Palli
It's actually... You know, I know politicians bet in betting shops. I know garbage collectors bet in betting shops. But sometimes the betting shop is at the end of the street. Sometimes the betting shop was a telephone. Other times the betting shop was Ascot racecourse and you're in the high-end blah blah blah.
- David
Yeah.
- Surya Palli
It just depends on which section you're in, what your capability and what you feel comfortable with. But it's all gambling. Prediction markets is the same. Doesn't matter whether you're, you know, deciding which year David Carradine's will retire...
- David
Yeah.
- Surya Palli
Or whether you're betting on, you know, who's going to win the World Cup. It's the same thing.
- David
Yeah. But do you think all our gambling rules should eventually will apply to prediction markets?
- Surya Palli
Absolutely.
- David
Yeah. I think...
- Surya Palli
Absolutely.
- David
I think some countries in Europe already are doing it.
- Surya Palli
Well, some people have banned it. Spain have banned it. Indonesia have banned it.
- David
UK is looking into it very quickly.
- Surya Palli
Donald Trump loves it. He's probably playing on it.
- David
Yeah, it's interesting though. I mean, because you know, especially caution polymarket they have taken over the business from FanDuel and DraftKings and other crypto companies as well. crypto.com, you know, there's a little bit of first mover advantage.
- Surya Palli
Yeah.
- David
You know, so it's still very early days.
- Surya Palli
Yeah.
- David
We'll wait and see.
- Surya Palli
Do you think there's still an opportunity for operators to bank on it or it's too uncertain at the moment?
- David
Every operator would make their own take their own legal risk and evaluation of what the opportunity is and what is likely to happen. Some people might just sit quiet and wait and see. And be building a strategy that is well thought through that will roll into this when there's some clarity. And if that's synergistic with their geographical focus, then it might be right for them. It might be right to stay out.
It depends on your situation and your capability and what else you do. For example, prediction markets here in the Philippines, I wouldn't waste my time.
- Surya Palli
Yeah. Yeah. Yeah.
- David
And so because it's a cultural nuance.
- Surya Palli
Yeah.
- David
It's too big a decision. Too... The audience is minuscule, yeah.
- Surya Palli
Yeah. So it really depends on the market, on the customer, where they are, and what's the regulatory progress over there. Cool. Okay, let's talk about business in general. Like, what is the advice do you have for anyone like me who is in early 30s starting a business with some hope just ahead of life. What is the thing that they need to keep in mind?
- David
Well, I think actually personal management of time and discipline is actually key. If you look at all of these famous people...
- Surya Palli
Yeah.
- David
The really rich guys, they all have a drive and they have a system and they have a process. Underpinning that process is simple time management practices. I've told people that I do a to-do list every day.
- Surya Palli
Wow.
- David
I update the to-do list.
- Surya Palli
Even today?
- David
Yeah. Before I go to sleep every night, I update the to-do list. And then I prioritize the to-do list. Now, even when I was in the prison, I did a to do list. I had a to do list. I had to coach somebody to write a CV. I had to do my exercise. I had to write six letters. I had to read one chapter of the book, whatever. I did a to do list. So for you, that discipline for your priorities incredibly important. It's not what you like doing.
It's not what people are telling you to do. It's what you decide to do.
- Surya Palli
You know, sometimes when we look at the market and when we whatever we're coming up as a product or a service, it's not always easy to understand if it will work. How can one make a decision in terms of I'm being selfish here, but you know... How do one make a decision in terms of if something would work or not?
- David
Well, there's a basic research and analytics and test. But you know the most important thing? Your gut feeling. Do you believe in this? Are you prepared to die for it? Not literally, but you know, lay yourself on the line. How committed are you to doing it? That's important.
- Surya Palli
David, thank you so much for joining me.
- David
Very welcome.
- Surya Palli
And sharing everything so openly as well as what it is rather than what it's supposed to be. That's how a lot of things happen in our industry. That's why I called it real talk to keep it as real as possible. So thank you for joining me here.
- David
Uh I'm very welcome and I'm very appreciative for the invite. Thank you.
- Surya Palli
So that's it guys. Share your thoughts in the comments below. Do follow David and I'll see you on the next one. Thank you.
- David
[music]
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