ICE Barcelona 2026 - Tim Miller Speech
19 January 2026
This speech was delivered by executive director Tim Miller at ICE Barcelona on Monday 19 January 2026.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Good morning everyone and thank you for that welcome. I’m really pleased that ICE has given so much focus this year to the risks that can come from the illegal market. I will say a bit about some of the work we at the Gambling Commission have been doing in this space over the last 12 months. Both how we continue to build our understanding of the risks and on how we are tackling it as well. However, I’m conscious that this topic is increasingly featured on conference agenda and in the trade press. So I also want to explore a slightly different angle today. It’s going to lead me to ask a simple question of some organisations that are perhaps trying to have their cake and eat when it comes to working with this industry. And that is ‘whose side are you on?’
Before I get to that though, let’s look a little closer at the work we’ve been doing to understand the illegal market better and why people gamble with illegal sites.
Last Autumn the Commission over the course of a couple of months published a series of detailed reports on what the illegal market looks like, who is playing on it and some updates on what impact we have been able to have in combatting it. Analysing data collected over 12 months, the report threw up many important insights. It shows what makes up the illegal market and demonstrates that motivations for gambling with it are more complicated than many suggest.
For example, our research is clear that a major part of the audience for illegal gambling websites and apps are people who are already self-excluded and I’ll talk more about the risks such consumers face in a moment. Amongst the other groups we identified were those who gamble on illegal sites for better offers or to use crypto and those who end up on illegal websites by chance.
And we also published further information on how we are taking action. There is of course more to do but between April and the end of December 2025 alone, we have:
Issued 592 Cease and Desists to advertisers and operators
Reported 327,964 URLs to various search engines and seen 203,571 URLs removed as a result so far
Referred 839 websites to the search engines for delisting
Disrupted 627 websites so that they have either been taken down or geo-blocked.
And all of that is without mentioning some of the other actions that our enforcement team take behind the scenes that we can’t discuss publicly.
So clearly a lot of work has already happened to better understand the illegal market, through a broad evidence-based approach. At the same time a lot of action has been taken by us to disrupt illegal operators from targeting consumers in Great Britain at scale. But we also need to think about where else we all need to focus.
The licensed industry is under threat from illegal operators. Consumers are under threat from illegal operators. The taxpayer is under threat from illegal operators. And in this battle between creating safe, fair, well-regulated markets on the one hand and harmful, exploitative, tax dodging criminal enterprises on the other there must be no option for people to have a foot in both camps. It’s time to pick a side and so we all need to start asking ‘Whose side are you on?’.
There is an increasing alignment between regulators and the legitimate industry in their messages around the importance of tackling the illegal market. But in the same way as regulators and governments always need to be alive to what unintended impact their approaches may have on channelisation rates, the licensed industry needs to reflect on what unintended role they themselves might be playing in growing the threat of the illegal market.
If we want consumers to make well informed choices and, if not experiencing harm, remain in the licensed market then there needs to be clear blue water between that and the unlicensed space. But at the moment the dividing line is being muddied by those that want to be a part of supplying legitimate, regulated operators yet are either indifferent to whether they also facilitate the illegal market or are actively seeking to play both sides.
Gambling regulators across the world are increasingly identifying suppliers, affiliates, advertisers, tech companies and others that work with licensed operators but who are also providing the same services to the illegal market.
As regulators we will seek to use the powers available to us to take appropriate action against those that facilitate the provision of illegal gambling. However, when pulling the lever marked ‘legal action’ there is a hard reality that dragging a cloud services company based in, say, California or an affiliate marketer based in Curacao through the domestic courts will not always be practical or possible.
That’s why alongside a regulatory or law enforcement response there is an important and essential role for industry to play. A role that is further upstream. A role with the aim of commercially strangling those third parties that facilitate unscrupulous operators to steal your customers or exploit vulnerable consumers.
As a global, regulated industry you have significant economic muscle and considerable commercial leverage. And for all of us here today with a shared desire to fight against the illegal market- well, I think we have overlooked this important and powerful weapon in our arsenal. And it’s time we deploy it.
Collectively, we need to make working with or suppling unlicensed operators commercially toxic. For me there are three key questions that any legitimate business in this industry could or perhaps should be asking themselves to help make that happen:
Firstly, how do you hardwire addressing the threats that the illegal market brings to your business through your procurement, contractual and commercial decision making?
Secondly, what due diligence are you doing with all of your suppliers and contractors to satisfy yourself that they are not working with your illegal, unregulated competitors?
Finally, what contractual provisions can you put in place to prevent them from working with illegal operators or to make the contractual consequences too great if they do?
To be really clear, I don’t make these comments as an implied threat of regulatory action against operators that don’t act. Yes, there are times where we will and have held operators accountable for the actions of their commercial partners. However, what I’m seeking to do today is drive greater common purpose, greater alignment, greater partnership between regulator and regulated in our shared desire to tackle the illegal market. Because in this space consumer protection really does go hand in hand with revenue protection.
Now, I appreciate that asking and answering those three questions I’ve set out may result in removing some of these suppliers from the marketplace and may then have short term impacts by causing some reduction in competition and consequential upward cost pressures. But I would argue that is a small price to pay…and not just because of the consumer benefits. Indeed, if the industry’s own warnings about the financial impact of the illegal market are even close to accurate then the costs of not acting will be considerably higher. Because:
If your affiliates are also driving traffic to the illegal market then you are helping to build the illegal market.
If you are using the same suppliers, such as webhosting companies, as the majority of illegal websites then you are helping to build the illegal market.
And, if you are marketing your products through platforms, including social media, that also promote illegal online casinos then you are helping to build the illegal market.
Which takes me to Meta, the owners of such social media brands as Facebook and Instagram. Anyone who spends even a little time on their platforms will more than likely have seen ads appearing in your feed for illegal online casinos. Most notably, and perhaps most worryingly, many of these aimed at GB users are for the so called ‘not on gamstop’ sites. These are targeted at consumers that have taken the often difficult step to self-exclude from online gambling through the use of GamStop, Britain’s multi-operator self exclusion scheme.
Now, companies like Meta will tell you that they don’t tolerate the advertising of illegal sites and will remove them if they are notified about them. But that approach suggests that they don’t know about those ads unless alerted. That is simply false.
Meta has a searchable ad library where you can find all current ads that meet searched key words. You or I can conduct such a search for ‘not on gam stop’ sites and see for ourselves how many are currently paying Meta to advertise on their platforms. It’s effectively a window into criminality. If we can find them then so can Meta: they simply choose not to look.
Now we have engaged with Meta on this and aside from a few warm words we have got very limited progress. Their suggestion was that we should deploy AI tools ourselves to monitor and find these ads and then report them. I would be very surprised if Meta, as one of the world’s largest tech companies is incapable of proactively using their own keyword facility to prevent the advertising of illegal gambling. It could leave you with the impression they are quite happy to turn a blind eye and continue taking money from criminals and scammers until someone shouts about it.
And in this global forum it is important to note that this is not unique to Britain but is repeated country by country. The situation we all face is that regulatory resources or tax payer money around the world is currently having to be spent on doing Meta’s job for them.
So it does leave Meta with the question of ‘Whose side are you on?’ The consumer and users of your platforms, many of whom are seeking to escape gambling harm, or the criminals and con artists who are using your platforms to prey on vulnerable people right in front of your eyes and whose clutches you risk pushing those vulnerable people into?
As I close I want to look ahead. As part of the Budget in November, the UK Government announced an additional £26 million of funding over the next three years for the Commission to fight illegal gambling. This is positive news and I think recognises the success we’ve started to have in this space in recent times and government’s confidence in us to continue the fight.
Besides extra funding promised, the Government’s Crime and Policing Bill is currently at Committee Stage in the House of Lords. When this is enacted it will give us powers to obtain orders to suspend internet protocol – or IP - addresses and internet domain names linked to illegal gambling.
But whilst this will allow us to build upon our existing actions, our planning is ongoing on what that will look like over the next few years. We are establishing a comprehensive programme for this work and will share more details as we move into the new financial year. It’s also worth remembering that the Commission alone won’t be able to solve the challenge of illegal gambling. Success will only come through strong collective action with government, with international regulatory colleagues, with industry and with others so that we can hit this criminal market and those who provide succour to it from as many angles as possible - using regulation, using prosecutions, using legislation, using technology, using commercial pressure, using hard powers, using soft powers. Using everything in our collective arsenal.
No one actor in this space can win this battle alone – we need to work together. We need to work together to ensure that there is no room for suppliers and other companies who want to benefit from the legitimate industry whilst also actively undermining our collective efforts to tackle illegal gambling operators. Government, regulators and industry should no longer tolerate anyone having a foot in both camps. It’s time to work together. It’s time to force them to pick a side.
Thank you.
Last updated: 19 January 2026
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