Confronting the threat: how we’re tackling illegal gambling in Great Britain
Our Director of Enforcement and Intelligence John Pierce outlines our enforcement and disruption activity in tackling illegal online gambling, highlighting the work of the Illegal Markets Team.
Posted 21 October 2025 by John Pierce
Our corporate strategy sets out a clear commitment to increasing investment, resources, and capacity to tackle illegal markets; and we’ve already made strong progress in that space. To shed some light on some of this progress, we have just released our third instalment of our illegal online gambling report.
Before focusing specifically on illegal gambling, I wanted to reflect on how much the work resonates with my previous experience in Trading Standards. The challenges we’re now facing are strikingly familiar to those long associated with other illegal markets, such as tackling the importation and sale of counterfeit goods. These markets share common traits: complex cross-border supply chains, significant economic harm, consumer detriment, negative impact on legitimate trade and links to organised crime. Investigations are often multi-stranded and present real challenges for an enforcement team to work effectively to co-ordinate action that inevitably crosses borders. The parallels are clear, and they reinforce the importance of a joined-up, strategic approach.
Dismantling any illegal market is notoriously difficult. It requires joint effort, creative thinking, and an acceptance that no single solution will be sufficient. Given the scale of revenue involved, it’s unlikely we will ever fully dismantle the ecosystem surrounding illegal gambling, which is increasingly sophisticated, digitally driven, and global in scale.
Unlicensed operators are actively targeting British consumers by manipulating search engine results, exploiting social media platforms, and integrating with payment systems. Many imitate legitimate businesses and take advantage of regulatory gaps across jurisdictions. This activity poses serious risks in Great Britain. It undermines consumer protection, distorts fair competition, bypasses regulatory standards, impacts tax revenue, and in some cases, is linked to organised criminal networks. Tackling it will require sustained, collaborative action and a clear strategic focus.
Alongside the risks associated with the targeting of vulnerable consumers through internet search terms such as ‘NotonGamstop’, we know unlicensed sites often lack age verification, responsible gambling tools, secure payment systems, and an appropriate dispute resolution scheme. Consumers face increased risks from unfair gaming practices, financial loss, and a lack of recourse if things go wrong. We are also aware that some illegal gambling sites are blocking payouts or setting withdrawal limits so high they’re unattainable. Separately, there are serious data protection concerns for players, with risks of identity theft and fraud.
The Gambling Commission is responding decisively and at pace by actively disrupting illegal gambling operations, strengthening our intelligence capabilities, and forging new partnerships across technological and financial sectors and with international regulators. At the same time, we are investing in our own organisational resilience—developing new tools, equipping our teams with the right skills, and deepening our understanding of the market through targeted research and data.
Strengthening partnerships and financial disruption
Our Financial Intelligence Team supports our illegal markets response and acts as a key link with law enforcement. We are already seeing results in relation to the targeting of financial accounts associated with illegal gambling, though the international nature of the issue presents obvious investigative challenges.
We have invested in specialist tools to support our Illegal Markets Team to conduct secure website reviews, anonymised access, and targeted test purchasing. These capabilities allow us to verify jurisdictional targeting, gather evidence, and assess the availability of illegal gambling products to British consumers. While we can’t review every site, this approach helps us focus on those we believe are causing the most harm, or where our disruption efforts will have the greatest impact. On a practical level, test purchasing remains challenging due to identification and payment verification requirements, but it provides critical evidence; especially banking details that can be referred to Visa and Mastercard. Work is also underway with PayPal, Google Pay, and Apple Pay to extend our reach.
To reduce visibility of illegal operators, we have developed referral pathways with major search platforms; Google, Bing, and Yahoo which together account for around 97 per cent of the Internet Search Engine (ISE) market in Great Britain. These partnerships enable automatic delisting of illegal content, intelligence sharing, and early disruption. While sites often reappear, this remains a valuable tactic.
We have also been expanding our efforts to include social media platforms like Meta, TikTok, X, and YouTube to tackle illegal advertising. Looking ahead, strengthening our understanding of advertising channels, financial flows and collaborating more closely with the financial sector will be key. Exploring options to develop joint initiatives with other regulators internationally is also taking place to develop a co-ordinated international response.
Illegal markets evolution: understanding and responding to key risks
Illegal operators are rapidly adapting their tactics, using domain rotation, cloaking, and embedding gambling content in unrelated websites. Some sites change their display depending on the device used, while others employ unusual advertising methods such as Google Maps to draw in users. These behaviours, while presenting new challenges, indicates that illegal operators are having to adapt their approach in response to our work and our interventions are having some impact.
Assessing traffic data from 160 websites targeted for enforcement action shows a 32 per cent drop in GB user engagement following reassessment after three months. Whilst positive, we recognise that disruption activity often leads to displacement elsewhere which requires us to actively monitor the marketplace. We have updated our processes by investing in data science techniques to automate how we extract and analyse consumer footprint data, helping us to respond faster and more effectively to illegal activity.
We recognise that the illegal market will continue to evolve, with trends including crypto-based payments, AI-generated branding, copied gaming content, and targeted social media promotions. Looking ahead, emerging threats like generative AI, deepfakes, and decentralised platforms will require us to further strengthen our technical knowledge and capabilities in future.
Adapting to an evolving threat
Illegal gambling is not a static threat—it is adaptive, opportunistic, and increasingly embedded in digital ecosystems on the international stage. Through targeted disruption, strategic partnerships, and continued investment in capability, we are building a resilient and effective framework to protect consumers and uphold the integrity of the regulated sector. We are making progress—and we are committed to going further.
We have included a few case examples in the report to show where our actions have made a real difference. While they represent just a small part of our overall work, they highlight real results—disrupting illegal operations, prompting platform action, and preventing consumer harm.
The insight we are providing is intended to give some context to the challenges we are facing in targeting online illegal gambling markets. By learning from the experiences of other regulators and law enforcement teams tackling similar problems—such as counterfeit goods—it’s clear there isn’t a single approach or quick fix. Addressing illegal gambling will take time, coordinated support, and sustained effort.
The threat will remain with us, and we must continue to find new ways to disrupt and adapt as online illegal markets continue to evolve and present new technological challenges.