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Have you ever come across a flashy TikTok gambling ad and wondered, “how old is this guy supposed to be?” Well, the UK’s Advertising Standards Authority just validated your instincts, proving that you were right on the money. The regulator recently ruled against Dribble Media Ltd, the company behind the online casino app Midnite, after a paid TikTok ad featured an AI-generated character who appeared to be under 25 while promoting a World Cup betting offer: bet £10 on a match, get £30 in free bets.
Interestingly, on the same day, the ASA made a contrasting decision that will resonate with fans of competitive gaming, specifically in the realm of esports: display ads for White Hat Gaming’s Casimba and The Grand Ivy Casino brands were cleared for running on HLTV.org, a popular hub for Counter-Strike 2 enthusiasts. One ad was banned, while the other was given the green light, shedding light on the fine line the ASA draws between gambling marketing that targets minors and marketing that coincidentally appears alongside esports content.
An Affiliate, an AI, and an Unauthorised Ad
The ASA’s ruling centered around a video posted on TikTok in July featuring a youthful-looking individual using the Midnite app and endorsing the World Cup free-bets promotion. Dribble Media, based in Gibraltar, disavowed the ad, citing branding inconsistencies, and clarified that the ad was created and disseminated by an affiliate, Limay Media Ltd. Subsequently, Midnite cut ties with Limay and committed to reinforcing compliance standards across its network of partners.
According to CAP Code rule 16.3, individuals who appear to be under 25 are prohibited from participating in gambling ads. This restriction applies regardless of whether the person depicted is real or not.
The Prompt Never Said “Make Him Look 30”
Limay Media explained to the ASA that the character was an AI-generated fictional entity, not an actual person, and that the directive did not explicitly specify an age of 25 or older, even though the intention was to portray an adult. The agency acknowledged an oversight in its approval process, attributing it to a singular mistake, and confirmed that the ad was retracted within hours. Measures have since been implemented to include age-specific directives and manual checks to verify the perceived age of generated characters before dissemination.
Despite these efforts, the ASA deemed the character’s youthful appearance, casual demeanor, and enthusiastic behavior suggestive of someone in their late teens or early twenties, with insufficient credible verification of his age. Both Dribble Media and Limay Media were instructed not to run the ad in its current form. This marks the third ruling against Midnite by the ASA this year, following a previous campaign that garnered 125 complaints for implying that gambling could serve as an escape from personal issues.
Same Day, HLTV.org Passes the Test
In a separate ruling involving White Hat Gaming, two banner ads for Casimba and The Grand Ivy Casino promoting a 100% match bonus up to £100 on first deposits were scrutinized for running on HLTV.org. The ASA determined that these ads did not violate CAP Code rules 16.1 or 16.3.13, reasoning that HLTV’s content and presentation were clearly geared towards an adult audience, leading to no further action being taken.
When juxtaposing these two rulings, it becomes evident that the proximity to esports content or the use of AI-generated characters, rather than human actors, is not the issue. What triggers a ban is the presence of a character on screen who appears more suited to a college dorm than a sportsbook, regardless of whether that character ever existed in real life.