It is argued that the analytical comparison of gambling regulatory frameworks across jurisdictions requires the identification of salient dimensions to provide the basis for such. It is further suggested that governmental ‘conflict of interest’ might provide a useful dimension for such comparison, as operationalised by concomitant EGM harm and government dependence criteria. The same ‘conflict of interest’ criteria are then suggested as a guide for gambling regulation within single jurisdictions, this being named the ‘Public Accountability Approach.’ These points are discussed within broader reference to lines and webs of harm production within a public health analysis. Broader reference is also made to the proper role of government within contemporary democracy.