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Industry Forum minutes for 24 June 2025

Minutes of the meeting of the Industry Forum, 24 June 2025.

[Remote] Illegal Markets Working Meeting.

Members:

  • Nick Rust (Chair)
  • Kirsty Caldwell
  • Charles Cohen
  • Ashley Padgett
  • Mark Pearson
  • Nigel Roddis
  • Leo Walker
  • Helen Walton
  • David Williams.

In attendance: REDACTED.

Apologies: Tony Boulton.

1. Welcome, apologies and declarations of interest

Apologies for the meeting were noted.

The IF Chair welcomed attendees to the meeting and introduced Gambling Commission officials who would be presenting on illegal markets.

The IF Chair gave a brief update on 2 actions from the last meeting:

  1. REDACTED.
  2. REDACTED.

2. Illegal markets

IF members received a presentation on the Commission’s key areas of focus on illegal markets for the next 12 months. Key areas highlighted as follows:

  1. Improved Illegal Markets processes and proactive response;
  2. Increased resources to support the Commission’s Illegal Markets work;
  3. Increased cease and desist activity;

REDACTED

  1. Further reporting to Google and Microsoft via the Government Portal;

REDACTED

  1. REDACTED
  2. Continued engagement with External Partners – Law Enforcement, Police Intellectual Property Crime Unit, HM Revenue & Customs, Financial Conduct Authority, Financial Sector, VISA, and Mastercard;
  3. Engagement with licensed software providers to disrupt licensed software being offered on unlicensed websites;
  4. Operator engagement; and
  5. Attendance at Internation Association of Gaming Regulators' (IAGR) Gaming Summit conference – strengthening the Commission’s engagement with other regulators internationally and sharing best practice.

Questions and comments arising from the previous points of the presentation were discussed:

  1. A lot of the work that the Commission currently carries out in the financial sector is very manual, but the Commission is aware that there is imminent work to be done to look at some of the software that the banks have in place (the Commission recognises that there is currently a knowledge gap here);
  2. There has been a rise in covert and sophisticated advertising on social media;

REDACTED.

  1. There is a lot of work that can be done around algorithms;

REDACTED.

  1. REDACTED;
  2. Some affiliates are advertising on websites that are not registered, and there are also examples of registration of websites taken over by groups who ‘dump’ an affiliate page as a front page;

REDACTED.

  1. The issue of streamers was also raised, for example people streaming videos of play on unlicensed sites through platforms such as YouTube and Kick. The Commission agreed that this was an issue they are aware of and stated that YouTube is very co-operative in responding to action requests from the Commission. A panel member referenced an example case in Denmark whereby a streamer had been levied with a criminal fine for this activity, following a joint operation between the regulator and the police. The Commission agreed it could look at creating a more stringent, personal process in this space, potentially working closely alongside the police to leverage their enforcement powers;
  2. Influencers and YouTubers promoting unlicensed gambling websites is another area to investigate;
  3. IF members had previously given feedback on a Commission document that was going to be published around the use and awareness of illegal sites. It would be useful to use this document as education for the public as well, on how to spot illegal sites and to remind them that if they do spot them and/or use them inadvertently they are not in trouble;
  4. Commission consumer research should be published in the summer, which will be the first step for the Commission to understand gaps and what is driving traffic to illegal websites;
  5. On affiliates, some affiliates are using genuine operator links (although not cash generating) on their website, to make the site appear legitimate. There is little that can be done to stop that. The Commission would be extremely interested to hear about any IF members’ organisations who have sent out a cease and desist to affiliates to see how the process works and how the industry and the Commission can work together in this area;

REDACTED.

REDACTED.

  1. It was suggested that the Commission should write to some of the bigger conference and events affiliates, for example IGB, reminding them that they should be expected to do checks on affiliate websites;
  2. On novel products, promotion of novel products seems to be on the increase in ad breaks on certain TV platforms (daytime and evening). Should this start happening on an even more regular basis, then this should be something for the Commission to consider in terms of what action could be taken to reduce promotional activity;

REDACTED.

  1. It would be useful if the Commission had a list of all novel products (which it does not currently have). The difficulty surrounding novel products is not to inhibit innovation necessary to the industry, whilst also ensuring that loopholes in regulation are not discovered and taken advantage of. Definitions can be troubling however, as they do not always encourage innovation. There is a real need to clarify exactly what novel products are, but without stopping innovation; and
  2. The Commission should encourage people to come forward with novel products. Some people want to be licensed but are being told they do not need to be as it is ‘not gambling’, and yet their customers are losing money.

Opportunities for Industry collaboration were discussed, such as:

  1. Leverage Industry relationships with key advertising tech companies and the financial sector;
  2. B2B supply chain;
  3. Role of affiliates;
  4. Disrupting supply chains and market access;
  5. Marketing ‘spikes’ – when, how, why;
  6. REDACTED;
  7. Cross Industry collaboration and intelligence sharing.

IF members raised questions and made comments on areas of potential collaboration between the Commission and the Industry:

  1. There is an area of work missing when looking at illegal sites when there are huge spikes of activity, where the Commission does not know what is causing those spikes. It would be beneficial for the Commission to tap into the Industry’s working knowledge and their advertising schedules in this space;
  2. REDACTED;
  3. The Industry is becoming more aware that tackling illegal markets is not at all straightforward and that such criminality can also be attached to bigger areas of criminality. This is something that has not been previously fully grasped by the Industry, but which is important to take into consideration;
  4. The Commission is looking to build out its illegal markets’ web page, but at the same time is not losing sight of land based;
  5. When ‘illegal markets’ is talked about, that can mean different things to different people and so it is important to tightly define what is meant by ‘illegal markets’;
  6. There are 2 reports on illegal markets that the Commission is publishing which will be circulated to IF members to sense check before publication; the first is on unlicensed gambling, which was due to be shared with IF members today however the timeline has slipped, and the second is a research-based report on what is driving traffic to illegal markets;
  7. The extent to which the Industry talks about illegal markets is used a lot in discussions, but if that is not helpful to the Commission then the Industry would want the Commission to feel that they have a vehicle to register that discontentment with the industry, and to have an open dialogue; and
  8. It is pleasing that a point has been reached where both the Commission, and the Industry appreciate how huge a topic illegal markets is. Industry support adds more weight to the work that the Commission is carrying out and further, the Commission needs ongoing support to get other regulators on board in tacking this very complex issue. The Commission still has a lot to do in this area.

REDACTED.

The topic of illegal markets is scored as one of the highest priorities for the Commission Board. Some additional resources are being brought in for this work as well as further investment in software and training. The Commission Board receives regular updates from enforcement on illegal markets and interaction has been very positive, with the Commission Board acknowledging that a lot of work has been done in this area but that there is still a great deal more to do.

3. AOB

There was no other business to discuss.

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