The Gambling Commission, that Great British authority responsible for regulating lotteries and commercial gambling, has published a discussion paper outlining its concerns about (among other things) unlicensed gambling using virtual game goods with real-money value -- especially on eSports.

The fact that the Commission is seeking to drum up discussion on the subject is especially notable given the recent uptick in popular attention paid to unregulated gambling rings around games like Counter-Strike: Global Offensive.

Bloomberg recently estimated that as much as $2.3 billion was wagered via CS: GO skins last year at websites like CSGOLounge, where users can bet in-game skins with real-money value on the outcome of competitive CS:GO matches.

Increasing public scrutiny of these operations also recently exposed some YouTubers and streamers who where promoting them without disclosing that they either had a stake in these gambling sites or were compensated to promote them.

Shortly thereafter Valve issued cease-and-desist letters to at least 23 CS: GO and Dota 2 gambling sites, which brings us back around to the Gambling Commission as some of those sites targeted by Valve (most notably, CSGOLounge) have said they will seek to bring their operations in line with gambling regulations and apply for gambling licenses.

"Like any other market, we expect operators offering markets on eSports to manage the risks – including the significant risk that children and young people may try to bet on such events given the growing popularity of eSports with those who are too young to gamble," stated Gambling Commission General Counsel Neil McArthur in a press release about the Commission's new discussion paper.

The Commission is seeking comments on the paper through the end of September, and it plans to issue a more definitive "position paper" on the subject before the end of the year.