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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.

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.

References

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.

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Case studies - Disruption of illegal online gambling 
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Conclusion and looking ahead - Disruption of illegal online gambling 
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