I can't see the Devs -- let alone FDev -- Sponsoring gambling in this game since the ESRB/PEGI is 10+. Gambling is for adults, not children.
Yes it is though genuinely not sure if a lottery counts as gambling as such. Monthly draw on a nominal weekly subscription, not exactly fixed odds betting machines, more tombola? I would think actually, if a youngster was to get into trouble gambling, could argue better to do that in a consequence free video game (with drug smuggling and murder in it too) than in the real world anyway.
I guess it's all seen as all very morally questionable gambling but you take a risk when you cross the street or stick your face in a fan and I'd go for bets on CGC superstars too personally, literally betting on the races and have the Ledger, the Derby., the Open! I think there's actually loads you could do, quite a lot genuinely entertaining with plenty of scope for "I told you so" and "the dealer always wins" conversations when someone loses their shirt .. and Anaconda.