Illegal online gambling: Disruption of illegal online gambling 

Introduction

This report explains:  

• our approach to disrupting illegal online gambling, so that this activity is difficult to operate at scale in Great Britain 
• early insight into the impact of this disruption 
• an overview of how we intend to develop our approach to disruption over the coming months.

Disrupting unlicensed gambling websites requires a coordinated approach to managing three key strands: Regulation and Investigation, Technological Advances and Marketing Strategy and Advertising. These strands each offer distinct methods of disruption, and while they can be pursued independently, their combined application significantly enhances impact.

The Regulation and Investigation strand involves legal and enforcement measures. These include identifying breaches of platform policies, engaging with licensing jurisdictions, conducting test purchases, tracking illegal sites, using OSINT, blocking payments, financial investigations and collaborating across borders. It also involves understanding the role of third parties and licensed business-to-business (B2B) suppliers in the illegal markets supply chain.

The Technological Advances strand focuses on the tools and tactics used by illegal operators. This includes indexing manipulation, VPN and proxy use, bespoke coding and automation, URL concealment, and the use of artificial intelligence to evade detection. The technical backbone includes DNS servers, website hosting services, and domain registrars, which enable the creation and accessibility of illegal sites.

The Marketing Strategy and Advertising strand targets the promotional ecosystem. Key actions include disrupting GB-based advertisers, publishers, and affiliates, enforcing advertising standards, partnering with search engines and social media platforms, and understanding how search engine optimisation (SEO) is used to drive traffic.

While each strand can be pursued on its own, the most effective disruption occurs when they are addressed together. This holistic approach allows our illegal markets team to apply pressure across multiple points in the illegal ecosystem, increasing the likelihood of meaningful and sustained impact.

We set out in the following paragraphs the various disruption points and methods adopted by the Commission’s Illegal Markets Team to target our disruption interventions across the supply chain to weaken the reach and resilience of unlicensed gambling operations.

When an unlicenced gambling website is identified, a Cease-and-Desist (C&D) notice is issued. The notice gives the operator 48 hours to implement geo-blocking or another method of preventing consumers in Great Britain from accessing the site. The 48-hour period was previously 14 days and has been significantly reduced which enables quicker disruption to take place.

The next step in disrupting these sites is to identify the registrar and host provider. A letter is sent to both informing them that they are hosting an illegal site. Different providers have different terms and conditions, but a common example is Cloudflare which will remove content proven to be illegal. Depending on the host and/or registrars’ policies, a site could be suspended for 90 days, or potentially longer even indefinitely.

Regardless of the results of the requests to the registrar and host all URLs associated with the site are sent to Google and Bing to be removed from search results in Great Britain. This ensures that if any of the pages have been indexed by the search engines, they will be removed from bing.com and google.co.uk. Importantly, sites where disruption has already occurred are revisited and reassessed on a regular basis to ensure the sites have not been made available to consumers in Great Britain again. If it has, a second round of disruption is initiated.

The Cease-and-Desist letters that are sent to the illegal operators, warn that the Gambling Commission may undertake test purchasing on their site. When test purchasing occurs, evidence is captured in a forensically sound way that proves the site was accessed from a Great Britain IP address. It also proves that a deposit in FIAT currency has been made, and those funds gambled on the site. This proves that the offence of offering facilities for gambling without a licence contrary to section 33 of the Gambling Act 2005 has been made out (opens in new tab)

The Gambling Commission works with partners to trace payments made on illegal sites during test purchasing exercises, the aim being to identify the person or organisation behind the illegal site. The Gambling Act 2005 gives the Gambling Commission powers to open a criminal investigation and to prosecute the relevant offences. However, our enforcement tactics are predominantly focused on disruption activity in most instances.

Summary of disruption activity

Since April 2024 the Illegal Markets team have issued:

• 3,140 Cease and Desist (C&Ds) and disruption notices (2,032 C&Ds, 774 Registrar referrals, 402 Host referrals, 3 payment provider referrals)
• 447,778 Bing and Google URLs referred (339,757 to Google and 108,031 to Bing)
• 287,961 URLs removed.

Figure 1 demonstrates that the level of disruption activity undertaken by the Gambling Commission between Quarter 1 (July to September 2024) and Quarter 4 (April to June 2025) has increased. 197 more websites have been referred to search engines for removal in Quarter 4 than Quarter 1 which in turn has increased the impact our work is having with 91 more websites being removed as seen in Figure 2. 

Figure 1: Enforcement activities to tackle unlicensed gambling undertaken July 2024 to June 2025

Enforcement actvities to tackle unlicensed gambling undertaken July 2024 to June 2025

Activity undertaken	Number of actions July to September 2024	Number of actions October to December 2024	Number of actions January to March 2025	Number of actions April to June 2025
Number of cease and desists issued to illegal operators	113	83	129	145
Number of cease and desists issued to advertisers and/or affiliates	130	122	29	77
Referrals to Registrars or hosts	113	80	105	147
Websites referred to search engines	124	144	209	321

It is also evident from Table 2 that the number of websites implementing geo-blocking measures following receipt of a C&D continues to grow. We are referring more websites to registrars and hosting providers which has led to an increase in the number of websites suspended.  

Figure 2: Outcomes of enforcement activity fromn July 2024 to June 2025

Outcomes of activity fromn July 2024 to June 2025

Outcomes	Number of actions July to September 2024	Number of actions October to December 2024	Number of actions January to March 2025	Number of actions April to June 2025
Number of websites geo-blocked by operator	37	77	66	108
Number of websites or advertisements removed by affiliates or advertisers	53	71	9	42
Number of websites removed and/or suspended by registrar or host	18	7	12	22
Number of websites removed from search engines	123	109	170	214

We recently published a report on understanding consumer engagement with illegal online gambling using web traffic estimates. This web traffic data can be combined with our recorded disruption activities to measure their effect on estimated engagement with illegal websites. The effect of disruption is calculated by taking the estimated engagement from the month preceding the disruption event and comparing that with the average monthly estimated engagement from the three months following the event.

Since multiple disruption activities can be taken against one website, it’s possible that when looking at a particular activity type in isolation, effects of another activity type are also being observed. However, this still provides an idea of which activities are more impactful.  

Referrals to search engines and social media companies are the most frequent disruption activities, along with GEO IP blocking.

GEO blocking and blocks by the registrar appear to be more effective methods of disruption. Removals from search engines still have an impact, but to a lesser extent. This is likely because removal from search engines make the website harder to find, but do not fully block access. GEO blocking and registrar blocks are more effective, provided that consumers are not accessing these sites using a virtual private network (VPN) in the case of GEO IP blocking. The data in the following table includes any illegal gambling websites that have had disruption action taken against the site since December 2024, where estimated web traffic data was available from SimilarWeb.

Table 1: Enforcement actvities to tackle unlicensed gambling undertaken July 2024 to June 2025

Enforcement actvities to tackle unlicensed gambling undertaken July 2024 to June 2025

Disruption undertaken	Average disruption effect (decrease in percentage)	Number of domains
Removed by google	30%	80
Removed by Facebook	8%	57
GEO IP blocked	60%	53
Removed by Bing	52%	28
Blocked by registrar	91%	8
Website suspended	91%	8

We have invested in specialist software to support website reviews and test purchasing activity, allowing us secure access to illegal sites while masking our IP address. This allows us to verify jurisdictional targeting and gather evidence to support enforcement decisions. Test purchasing is a key part of our proactive monitoring programme and helps us assess the availability of gambling products consumers in Great Britain. 

We are also expanding our disruption efforts across major platforms such as Meta, TikTok, X (formerly Twitter), and YouTube. Targeting is informed by traffic data from SimilarWeb, and formal data requests may be submitted to support case development. In the quarter from April to June 2025, 84 illegal lottery URLs were removed from social media platforms, and 108 Illegal lotteries were referred to social media platforms. These actions are designed to reduce visibility of illegal gambling content and prevent consumer harm. 

Collaboration is central to our approach. We work with international regulators through bodies such as the International Association of Gaming Regulators (IAGR) and the International Association of Gaming Advisors (IAGA), sharing our methodology and supporting global efforts to tackle illegal gambling. We have also established working relationships with Microsoft and Google to streamline referral processes and improve search engine coverage. 

Although still in its early stages, reporting payment transaction data to the Visa Operator Scheme is a critical element of our enforcement strategy. This capability allows us to identify and disrupt payment flows to businesses involved in illegal gambling activity. As we scale this approach, it has the potential to significantly enhance our financial disruption toolkit and strengthen our ability to disrupt payment services associated with illegal gambling activity. 

We are planning additional test purchasing activity, prioritising high-traffic platforms and remain guided by financial intelligence that highlights suspected illegal gambling operations. This approach is designed to intensify disruption efforts while also advancing our insight into the complex and frequently international financial structures that support such activity. 

Industry engagement is also an important area of focus. We are working with licensed operators to understand how legitimate marketing practices are performed. It is believed that these practices are mirrored in the illegal marketplace — including the replication of promotional tactics, bonus structures and user journeys. This insight from the regulated sector helps us target disruption where it will have the greatest impact.  

Alongside this, we have been clear that we expect all licensed Business-to-business (B2B) and Business-to-consumer (B2C) suppliers to take proactive steps to prevent their products from being supplied to unlicensed websites targeting consumers in Great Britain.  On 20 January 2025, we issued an Industry Warning Notice highlighting the appearance of licensed games on illegal sites. We expect Licensees to monitor their business relationships, terminate non-compliant arrangements, and notify the Commission where such activity is identified. Where games are found to be supplied to illegal operators, we will act — and that action will have a direct regulatory impact. 

We also expect licensees to notify the Commission if they become aware of any investigation by another regulator into the presence of their products on unlicensed websites targeting consumers in Great Britain. Failure to report such investigations may itself be considered a breach of licence conditions. The Commission uses this information to assess risk, prioritise enforcement activity, and ensure that licensees are taking appropriate steps to prevent their products from being misused in the unregulated space. 

Together, these enforcement efforts and regulatory expectations reflect a coordinated approach to tackling illegal gambling—where both the Commission and licensees have a duty to prevent the supply of products to unlicensed operators and to act decisively when breaches occur. 

We recognise that this work is at an early stage, but the signs of progress are encouraging. We remain committed to building our capability, sharing our approach internationally, and working with industry to protect consumers and uphold the integrity of the regulated market. 

While our approach is still developing, we are already seeing signs of impact. Illegal operators are beginning to adapt their tactics in response to our interventions — including changes to how URLs are structured, the use of rotating domains, and embedding gambling content within unrelated websites.  These behaviours indicate that our disruption efforts are having an effect and are prompting evasive action. As the illegal marketplace evolves, we will remain alert to these changes and continue to adapt our strategy to ensure we respond quickly to emerging threats. 

By combining records of past disruption activity with the web traffic data for each website, it is possible to estimate the effect our disruption has on the engagement with these websites.  

Web traffic data is available for approximately 160 illegal gambling websites that have had disruption activities taken against them.  

By observing the engagement with each of these sites in the month before the disruption activity was performed and comparing that with the average monthly engagement of the following three months, we can see how effective this disruption was. On average, across all 160 websites, there was a 32 percent decrease in engagement following disruption.

Case studies

New tactics coming into use

We recognize that, due to regulatory investigative findings, together with technological advancements to online networking and infrastructure and evolving marketing and advertising strategies employed by unlicenced websites, our tactics must remain dynamic and responsive. It is essential that we regularly review and adapt our approach. Below are examples of some of the new tactics being adopted by the Illegal Markets Team.

Referrals

The Gambling Commission seeks to create new referral routes with platforms used to host unlicenced gambling content.

Where existing removal routes are in place, the Commission now seeks to use our knowledge of engine and platforms policies to ensure we maximise what can be requested. By using several additional routes, the Commission will not only make legal requests for content removals, but to request further information on those running the illegal sites.

Illegal gambling sites are often operating in breach of internal policies of the platform they are using, and through submissions that evidence such breaches, further actions can be enforced against websites, decreasing their visibility to the Great British market.

International coordination 

Websites targeting the Great Britain consumer base illegally often hold licences in several overseas jurisdictions. 

More jurisdictions are now updating or introducing their licencing regimes for online gambling and there is set to be a shift of illegal activity to other overseas areas where licence conditions are less stringent, or markets are emerging. Another concern is that although the licences are held in jurisdictions with fewer requirements than Great Britain, the operators themselves could be based anywhere overseas, this presents challenges in terms of establishing their true operating locations.  

As we develop our understanding of the illegal market, continued international collaboration with regulatory partners represents a growing area of focus for the Commission.  The Commission was responsible for the creation and leadership of the International Association of Gaming Regulators (IAGR) working group, which has led to bilateral relationships with regulators, which is seeing steps taken to commence joint action against unlicenced sites affecting multiple jurisdictions. The group also offers an area for sharing best practice and addressing emerging issues that are being seen internationally.

The Commission has recently commenced a cross-working project with the Netherlands regulator, the Kansspelautoriteit (KSA) putting into action several exercises which all look to align our regulatory response to unlicenced websites which target both jurisdictions. Through several initiatives which aim to address a broader range of co-ordinated disruption to that seen in previous years.

By working together to coordinate and target disruption activity, we can more effectively address operators licensed in other jurisdictions who seek to illegally access the GB market. Strengthening intelligence-sharing and developing operational ties with overseas regulators is an increasingly important tool in our response to illegal activity — and a critical stand in tackling such threats at a global level. 

Calls to relevant regulators for action against sites illegally targeting the Great British market

Using evidence gained through increased Test Purchase activity of the offence committed, the Commission will issue correspondence to the body responsible for licensing the website. Where the site to be referred is also found to be offering illegal gambling facilities to another jurisdiction, the Commission may send such requests through collaboration with other IAGR members affected to the regulator in question, strengthening the call for action to be taken against the operator responsible.

Use of coding

Using Python, the Commission continues to build on bespoke tools which once built will allow for automation of tasks and scripting, in depth data analysis and Machine learning. The use of such coding tools has already seen the creation of a bespoke report using Application Programming Interface (APIs) from a variety of sources to create a monthly PowerBi report by Commission data scientists for use by the Illegal Markets team. By using Python, tools needed to extract data from sites are being scripted which will allow a deeper level of data to be scraped from sites which can then be used in removal requests to platforms and search engines.

Further payment blocking coming into use

In January 2025, following a successful test-purchase exercise on an unlicensed website, the Commission made its first referral to Visa. Since then, the Commission has made a further 3 referrals, relating to 3 separate unlicensed websites.

Referrals are made to Visa where it is identified that an unlicensed website is offering Visa payment for the deposit and/or withdrawal of funds from the website. A referral to Visa can only take place once a successful test-purchase exercise is carried out; it is not possible to simply signpost them to the website because they need the associated financial data to take action. Evidence of a successful test-purchase transaction carried out by the Commission must be provided to support the referral.

Upon receipt of the Commission’s completed referral, Visa commence their own investigation that allows them to trace the transaction to an acquirer¹ and raise a compliance case against them. It is the Commission’s understanding that the acquirer is then mandated to respond to the compliance case and terminate any dealing with the rogue merchant. In practice, this means that the unlicensed website that the referral relates to can no longer process Visa payments.

As the referral process with Visa has now been solidified it is gradually becoming a commonly used disruption method it is the Commission’s intention to duplicate this disruption method with Mastercard. The foundations have been laid through inter-organisational conversations to provide the Commission with a route into Mastercard, where referrals can be made and much like with Visa, be dealt with expeditiously by a dedicated team.

Although Visa and Mastercard payments are currently the focus of the Commission’s attention, we anticipate that payment provider disruption can be expanded to include digital wallets such as PayPal, Google Pay, Apple Pay, and so on.

Furthermore, the Commission is acutely aware of the emerging prevalence of cryptocurrency as a regularised form of payment across the illegal marketplace due to its anonymous nature. When this is combined with research completed by the Financial Conduct Authority (FCA) (opens in new tab) which shows that 12 percent of UK adults now own cryptocurrency, up from 10 percent in previous findings, it is clear that cryptocurrency payments in the illegal market is an area that must be considered in the Commission’s disruption work.

Focus on aggressive marketing tactics used by unlicenced sites

Aggressive marketing campaigns using unethical tactics are often used by unlicenced sites to maximise their visibility to internet users, and methods used expose users who are often not online for the purpose of visiting any gambling website, licenced or not. The high visibility of illegal sites is achieved through campaigns using highly trusted sites and linking via other resources as a tool to reach a wider audience base through unethical search engine manipulation tactics. The intricate linking strategies, combined with other web architecture manipulation practices has led to an additional Cease and Desist notice now starting to be developed to specifically focus on the targeting of digital marketing associated with illegal gambling websites.

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¹An acquiring bank (also known simply as an acquirer) is a bank or financial institution that processes credit or debit card payments on behalf of a merchant. The acquirer allows merchants to accept credit card payments from card issuers such as Visa, MasterCard.

Conclusion and looking ahead

Through collaborative work across internal departments, the Commission has built a multi-disciplinary approach to effectively understand, measure and enforce disruption tactics reflecting the complexity of current illegal techniques employed by site owners. 

We will continue to build on, and develop our strategy to tackling illegal markets activity as our knowledge base continues to increase and we test the effectiveness of the disruption methods currently being used.

We will continue to engage with local and international agencies to increase our knowledge on overseas licence holders, and to align our responses to sites operating illegally across both jurisdictions  

We will look to use web traffic tools data that can be added to reports coded to enforcements requirements, with monitoring of activity to provide contemporaneous data informing action. 

We recognise the emergence of AI and will continue to explore opportunities to continue to automate and target sites causing the most harm.

We also continue to work closely with the Department of Culture, Media and Sport (DCMS) and other government departments in relation to new powers proposed to tackle illegal online gambling, including the Government’s proposed Crime and Policing Bill, which is currently moving through Parliament. This new legislation proposes new powers to be made available to the Gambling Commission to make a court application that, if granted, would provide the ability to block access to an illegal gambling website using a method called Domain Name System (DNS) blocking.

Collaboration with stakeholders remains an important aspect of our work to understand and disrupt illegal online gambling. Data sharing arrangements, and collaboration opportunities with international gambling regulators will help to reinforce our disruption approach and build a more comprehensive picture of the illegal online gambling market.  This work will not only continue to contribute towards how we test and develop our response, but will also identify emerging threats, international targets and future opportunities to disrupt illegal online operators across multiple jurisdictions at the same time.

In addition to these measures, we recognise the significant role that advertisers and technology providers can play in helping to disrupt illegal gambling activity. While we are already working constructively with a number of platforms, the scale and sophistication of the issue mean further engagement is essential. We are exploring ways to strengthen these partnerships to reduce exposure and access to illegal sites.

We also see a valuable opportunity for industry to continue to support our efforts by sharing intelligence about illegal markets activity having an impact and to also gather insight into marketing and advertising strategies associated with the regulated sector. Alongside our existing approach, this collaboration will be vital in ensuring we continue to tackle illegal activity causing the most harm and develop our wider understanding of the marketing and advertising techniques being deployed or copied by illegal markets actors. 

Alongside this, we will continue to deploy our current disruption tactics and publish quarterly outcomes data that provides insight of our disruption work, ensuring transparency and accountability as our approach continues to evolve. 

Anyone with information about illegal gambling activity targeting consumers in Great Britain is encouraged to contact our Intelligence Team confidentially via: 

• Emailing our intelligence team
• the Tell us something in confidence portal.