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Report

Exploring online, illegal, individual-led lotteries and raffles

Exploring online, illegal, individual-led lotteries and raffles

  1. Contents
  2. Findings
  3. The off-platform journey

The off-platform journey

Payment usually happens off-platform, where familiar methods create a false sense of reassurance

Evidence from the qualitative and digital phases suggests that, once players decide a draw feels legitimate enough to enter, they are usually sent off-platform to complete payment. This often happens through external websites, payment links, PayPal flows or bank transfers.

For many, this did not feel unusual. Instead, it often mirrored everyday online payment journeys and could therefore feel routine, convenient and, in some cases, more official. Where the destination looked polished and the process was quick and familiar, players often paid limited attention to where they were being sent, provided the draw had already passed their initial trust threshold.

As one participant explained:

"It was as if you were buying something from Amazon, you know, just like a normal purchase…"

– Participant taking part in an illegal lottery, Facebook, Female, 41 years old

Another participant mentioned:

"Sometimes they have a raffle website and I do not pay much attention to it, if I’m honest. I just go on the website and buy the ticket."

– Participant taking part in an illegal lottery, TikTok, Male, 33 years old

In the survey, PayPal was the most commonly used payment method, followed by debit card payments and TikTok gifts. Bank transfers, TikTok coins and credit cards were also mentioned by a sizeable minority. Cryptocurrency was used less often overall but was more commonly reported among those with PGSI 8 to 27.

While TikTok Gifts and cryptocurrency were not mentioned spontaneously by participants during the qualitative interviews, incidence rates from the survey suggest these are emerging payment methods to watch, as they may be less regulated. The rates for payment methods that online individual-led lottery and raffle participants report using can be seen in Table 4.

Table 4: Which form(s) of payment do you use when taking part in, see being accepted on, and/or accept when hosting online individual-led lotteries or raffles via TikTok?

Table 4: Which form(s) of payment do you use when taking part in, see being accepted on, and/or accept when hosting online individual-led lotteries or raffles via TikTok?
Forms of payment used or seeing being accepted for online individual-led lotteries and raffles People using the payment method (percentage)
PayPal 49%
Debit card (including Apple Pay and/or Google Pay) 35%
TikTok gifts 30%
Bank transfer 29%
TikTok coins 27%
Credit card 26%
Cryptocurrency* 16%
Using in-game items, including skins 9%
Other 5%
*Cryptocurrency is higher among those with PGSI 8 to 27 (24 percent)

Base: All who have engaged in a TikTok raffle (395)

A low-friction journey may feel convenient, but can leave vulnerable participants more exposed

Evidence from the qualitative and digital phases suggests that the absence of checks commonly associated with licensed gambling, such as identity verification or Anti-Money Laundering (AML) checks, can make it faster and easier to move from discovery to payment. For many participants, this did not trigger concern. Once a draw felt legitimate enough, the smoother journey was often interpreted simply as more convenient.

Familiar payment methods could reinforce this further, particularly where participants felt that money might be recoverable if something went wrong.

This creates an important tension. The journey can feel safer because it is smoother, when in practice that smoothness may reflect the absence of protections players would normally encounter on licensed sites.

For some, paying through PayPal or a bank card appeared to create reassurance because these methods were associated with chargebacks, payment disputes or the ability to contact a bank or payment provider if a problem arose.

Digital intelligence also surfaced examples of potential risk among people already vulnerable to gambling-related harm, particularly through the off-platform journey. This unregulated ecosystem can leave players vulnerable to financial loss and scams, while also making it harder to know what recourse is available if something goes wrong.

This suggests that while a smooth experience may feel convenient or even reassuring to many participants, it can be actively harmful for those already vulnerable to gambling-related harm by removing key pause points and protections. In practice, the low-friction, off-platform journey can encourage impulsive participation and make recourse harder when problems arise.

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Trust and legitimacy 
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Awareness of legality
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