Report
Illegal online gambling: Disruption of illegal online gambling
The third chapter into the Gambling Commission's research in to illegal online gambling focusing on the disruption of the market.
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.
Previous sectionContents page Next section
Summary of disruption activity - Disruption of illegal online gambling
Last updated: 21 October 2025
Show updates to this content
No changes to show.