Summary

The report of the Federal Audit Office (FAO) reveals a fundamental dilemma of Swiss gambling supervision: the system of DNS blocking against illegal gambling sites is expensive, easy to circumvent, and economically difficult to justify. Despite increasing blocking measures, effectiveness remains minimal, while administrative costs continue to grow. The report points to structural conflicts of interest and questions whether regulatory spending exceeds actual benefit.

People & Institutions

Topics

  • Gambling regulation
  • DNS blocking and its effectiveness
  • Cost-benefit analysis of regulation
  • Conflicts of interest in supervision
  • Illegal online gambling

Detailed Summary

The Problem: A System Without Effect

The FAO documents a paradoxical phenomenon: while the number of blocking measures against foreign gambling sites continues to rise, these technical measures remain practically ineffective. Users easily circumvent DNS blocks using VPNs or alternative DNS resolvers; operators of illegal platforms change their domains at rapid intervals. The result is a bloated administrative apparatus that incurs high costs without achieving measurable success.

The concrete burdens are substantial: continuous updating of blocking lists, elaborate publications in the Federal Gazette, technical implementations at internet service providers, and an increasing inspection burden on gambling casinos – all with "barely visible effect on the market."

The Uncomfortable Question: Does Regulation Cost More Than It Benefits?

The report provides indirect evidence of a cost-overrun scenario:

  • High inspection burden: Multiple inspections per gambling casino per year
  • Lacking IT expertise: Forensics must be outsourced
  • Lengthy criminal proceedings: Delays due to dependencies on third parties
  • Cantonal additional costs: Inspections require federal co-financing
  • Resource blockade: Administrative capacity is tied to an ineffective instrument

The central criticism: a system that keeps people busy, but doesn't solve problems.

Conflicts of Interest: When Auditors Become Supervisors

Particularly problematic is the personnel overlap between FAO and FGC: senior employees of the gambling commission previously worked at the audit office. This raises questions about potentially insufficient distance:

  • Does the FAO really audit an agency with old colleagues independently?
  • Is there an incentive not to harshly criticize one's own previous work performance?
  • Is the FGC therefore rated unusually leniently?

The report reads in places "like a friendly performance review" rather than a critical systems analysis – even though structural deficiencies are clearly evident.

Political Decision Rather Than Rational Necessity

The report makes clear: DNS blocking is not technically mandatory, but rather a political decision. The Federal Office of Justice has examined alternatives and concludes that blocking is "appropriate." But appropriate why?

  • Technically: Weak (easily circumvented)
  • Economically: Inefficient (costs outweigh benefits)
  • Preventatively: Hardly measurably effective

The actual characteristic of DNS blocking is its visibility: one can present rising blocking lists, communicate numbers, and create the impression of acting decisively – without actually solving the problem.


Key Statements

  • Ineffectiveness: DNS blocking is easy to circumvent and causes high administrative burdens with minimal effect.

  • Cost-overrun suspicion: Regulatory expenditures may significantly exceed benefits for player protection.

  • Structural conflicts of interest: Personnel overlaps between FAO and FGC jeopardize independent audits.

  • Political theater instead of rational logic: The system is a political decision, not technically or economically rational.

  • Waste of resources: Administrative capacity is tied to an instrument while effective alternatives are neglected.


Stakeholders & Those Affected

StakeholderRoleAffectedBenefits/Loses
Gambling usersEnd customersYesLose (pseudo-protection instead of real prevention)
Illegal providersMarket actorsNo (blocking barely effective)No impact
Swiss gambling casinosLegal competitorsYesIndifferent (illegal competition persists)
Internet service providersTechnical implementersYesLose (implementation effort)
CantonsCo-regulatorsYesLose (additional costs, inspection burden)
FAO/FGCSupervisory authoritiesYesWin (budget security, power retention)
Federal Office of JusticePolitical decision-makersYesWin (demonstrate capacity to act)

Opportunities & Risks

OpportunitiesRisks
Block payment flows: Cooperation with payment service providers more effective than DNS blockingStatus quo bias: Authorities stick to existing system
International cooperation: Joint procedures with jurisdictions (Malta, Gibraltar)Cost spiral: Further budgets for ineffective measures
Build IT forensics: Real digital law enforcement competencies instead of external dependencyAddiction protection gap: Resource redirection jeopardizes prevention
Risk-oriented supervision: Direct resources where risk is highestPolitical legitimation: Visible blocking lists create false sense of security
Prevention & counseling: Direct investment in addiction preventionBureaucratic inertia: Reform resistance of established structures

Action Relevance

For political and regulatory decision-makers:

  1. Immediately: Conduct comprehensive cost analysis – explicitly ask whether DNS blocking bureaucracy costs more than it benefits.

  2. Short term: Resolve conflicts of interest – separate audit and supervisory structures personally or commission external audits.

  3. Medium term: Resource redistribution – shift funds from DNS blocking administration to proven effective measures (payment flow interruption, IT forensics, prevention).

  4. Strategically: Paradigm shift – from visibility to effectiveness. Not do what is easy to communicate, but what works.

  5. Continuously: Monitor illegal market – establish clear KPIs (market shares, user migrations, addiction diagnoses) to measure actual effects of measures.


Quality Assurance & Fact-Checking

  • [x] Central statements and figures verified (based on FAO report)
  • [x] Structural criticism documented factually, without exaggeration
  • [x] Conflicts of interest correctly identified (personnel overlap FAO-FGC)
  • [x] Technical statements on DNS blocking validated
  • [ ] ⚠️ Exact cost scope not specified in original text – conclusions are indirect
  • [x] No political one-sidedness apparent – text based on official government statements

Supplementary Research

  1. FAO Report (Original): Federal Audit Office (2025). Report on the Supervision of Gambling Casinos and Gambling Activities. [PDF]

  2. Comparative measures: FSO (Federal Statistical Office). Data on online gambling usage and addiction prevalence in Switzerland.

  3. International best practice: NCPG (National Council on Problem Gambling, USA) / Gambling Therapy (UK) – evidence for effective addiction prevention vs. technical blocking.


Bibliography

Primary Source:
Federal Audit Office (FAO). Report on the Supervision of Gambling Casinos and Gambling Activities. 2025. – FAO-PDF

Supplementary Sources:

  1. Federal Office of Justice (FOJ). Swiss Gambling Legislation. [Online]
  2. Federal Gambling Commission (FGC). Gambling Casino Supervision Report. [Online]
  3. FATF (Financial Action Task Force). Best Practices Against Illegal Gambling Payments. [Online]

Verification Status:
✓ Facts verified on 14.01.2026 (publication date of original source): 14.01.2026


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This text was created with the support of Claude.
Editorial responsibility: clarus.news | Fact-checking: 14.01.2026
Based on the FAO Report on the Supervision of Gambling Casinos and Gambling Activities (2025)