White Hat Gaming were also reviewed by ASA for age-restricted promotion but the ruling was not upheld.
On Wednesday the UK’s Advertising Standards Authority (ASA) ruled against Midnite following an investigation into a paid TikTok advertisement featuring an AI-generated character who appeared to be under the age of 25 and engaging in gambling activity.
The ASA reviewed a clip posted to TikTok in July promoting Midnite, a Gibraltar-based online casino app. The clip displayed a young-looking man using the app, accompanied by the voiceover: “Another massive World Cup upset. Bet £10 on the big match and get £30 in free bets. Level up your World Cup with Midnite, get on it.”
According to the ASA’s Code for gambling advertising, anyone who “was, or seemed to be, under 25 years of age” must not be depicted gambling or playing a significant role in advertisements.
The regulator concluded that the central figure’s youthful facial features, casual styling and excited demeanour gave the impression he was in his late teens or early twenties.
As such, the ad violated rule 16.3 of the CAP Code (Edition 12).
Midnite’s operator, Dribble Media Ltd, stated that the ad had not been authorised by their company. They cited discrepancies in branding and asserted that it was created and disseminated by an affiliate, Limay Media Ltd, without Midnite’s approval.
Midnite confirmed it had terminated its contract with Limay and would reinforce compliance reminders to its partners.
Limay used AI-generated character
Limay Media acknowledged that the person depicted was an AI-generated fictional character rather than a real individual and claimed the design was intended to appear as an adult.
The company admitted to lapses in its internal approval process, described the error as isolated and noted the ad was removed within a few hours.
Limay reported implementing new safety measures for AI-generated gambling creatives, including specifying age-related prompts and reviewing the perceived age of AI outputs.
Despite these measures, the ASA found that the character’s age was not credibly verified. The prompts used to generate the AI image did not explicitly require the character to appear aged 25 or over. Without an independent verification process, the regulator determined the character still “seemed to be under 25”.
The ASA’s ruling directed both Dribble Media and Limay Media to ensure the offending advertisement would not be redisplayed in the same form.
This is Midnite’s third ASA ruling this year. Last month, the operator came under scrutiny for an ad that suggested that “gambling was an escape from personal problems”. The ASA received 125 complaints on the offending ad and the company was ordered to remove the advertisement.
Another June ruling was not upheld.
White Hat Gaming’s display ads not in breach
In a separate case, the ASA examined display advertising for White Hat Gaming’s Casimba and The Grand Ivy Casino brands, which had appeared on HLTV.org – a specialist Counter-Strike 2 e-sports website – in March 2026.
Two banner ads promoted a “100% match bonus up to £100 on 1st deposit” and displayed the mandatory 18+ logo. The ads appeared alongside live match coverage featuring betting odds and sponsor logos, including a link to Casimba’s website.
A complaint suggested that such placements were inappropriately targeted at under-18s.
White Hat Gaming paused the ads during the investigation and argued that HLTV’s audience is primarily adult and focused on professional competitive gaming rather than casual play, which tends to attract minors.
HLTV corroborated this, highlighting its editorial tone as adult-oriented.
The ASA reviewed whether the ads were directed at under-18s through their placement or content. Its rules prohibit advertising through media where more than 25% of the audience is likely to be under 18.
While the audience data did not conclusively define the website’s age demographics, the regulator noted small percentages of under-18s in HLTV’s social channels but found the website’s content and presentation clearly targeted adults.
Ultimately, the ASA ruled that the ads did not breach CAP Code rules 16.1 or 16.3.13 and took no further action.
Kathryn Evans
Kathryn covers bitesize breaking news with a primary focus on EMEA and US legislation. A proud North Walian, fluent Welsh speaker and lifelong Wrexham FC fan – long before Hollywood came calling.
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