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Šimon Vincze: Exploring the effects of illegal gambling on the regulated industry

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In his latest piece for iGaming Expert, Šimon Vincze, Head of Sustainable & Safer Gambling at CasinoGuru, tackles a controversial subject as he examines what the gambling ecosystem would look like in the absence of the illicit sector.

There has been a new type of discussion centred around the positives, or rather, the legitimacy of illegal gambling. Perhaps controversial for some, but definitely interesting. It is a question of principle, law, and morality as well as cause and effect. One thing is sure: the illegal market keeps us on our toes and forces us to collaborate in tackling it.

It reminds me of my university years when I studied international politics. During a lecture on globalisation, someone asked whether it was possible to attain complete unity. The professor responded with cold confidence that it would only happen if there were a substantial external threat, likely from outer space, naturally, aliens.

Fast forward 15 years, and I am no longer so sure about that. You don’t need to be a superintelligent extraterrestrial to understand that people are easily manipulated. Thankfully, there is no propaganda claiming that illegal gambling is here to save us. Still, you must admit that some effects of its presence push the industry forward.

How would the gambling world look if it were not so easy to play at offshore operators? I find it exciting to think about it, but I dare not draw any conclusions. However, I will most probably not be writing this article, and we would know much less about the gambling experience that is exciting, but safe(r) at the same time.

Measuring the threat

After a brief philosophical warm-up, let’s examine the size of the hydra. As I have heard people refer to it recently, because each time you shut down one illegal channel, two new ones emerge. This is especially true in social media environments that are difficult for authorities to regulate but remain popular among younger generations.

Recent global meta-analyses of over 3500 reports show that nearly 18% of adolescents have gambled in the past 12 months. I believe the actual number of those exposed to gambling or gambling features is considerably higher.

Without considering different age groups, the American Gambling Association stated in their report that 48% of respondents had bet on illegal offers. This was in 2022, while a more recent estimate from Yield Sac claims that offshore gambling accounts for 74% of US gross gambling revenue. Additionally, a recent report in Sweden suggests that channelisation rates for online casinos have fallen to between 72% and 82%.

Casino Guru’s analyses of Google searches for specific casino brands reveal that more than half of these are directed towards illegal operators in the Netherlands. Our data shows a rise in such searches following the introduction of deposit limits in October 2024. Other countries are not performing well either, with around 20% of illegal searches in the United Kingdom and Sweden, and nearly a third in Spain.

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UK gambling nets full cooperation for Safer Gambling Week

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Safer Gambling Week 2025 (#SGWeek2025) takes place this week (17-23 November), with all UK gambling stakeholders expressing their full commitment to promoting safer play and responsible gambling.

Entering its ninth consecutive year, the initiative is co-led and coordinated by the Betting and Gaming Council (BGC), amusement trade body BACTA, the Bingo Association – and all other memberships associated with UK Gambling.

Last year’s edition highlighted that over 1.5 million unique accounts used a safer gambling tool during the week, which was a 22% YoY increase. The number of people who set deposit limits went up by 14%.

Furthermore, more than 60 million impressions on online safer gambling messages were generated across the biggest social media platforms – X, Facebook, LinkedIn and Instagram. It is safe to say that the organisers will aim to break these records in 2025 in the week running from 17 to 23 November.

Baroness Twycross, UK’s Minister for Gambling, said: “As a Government, we are fully committed to reducing harmful gambling and protecting those at risk. That is why we have introduced a statutory levy aimed at providing funding to tackle this.

“We welcome the contribution that Safer Gambling Week makes. It provides a good opportunity to highlight the tools and support that is available to people who may need it.”

Also engaging with the campaign was Andrew Rhodes, CEO of the UK Gambling Commission, who reiterated the importance of this week’s activity for the industry and its commitment to consumer protection.

“While progress has been made, we must continue to ensure that the tools and protections available to consumers are effective and widely promoted.

“Collaboration and evidence-based action remain central to making gambling in Great Britain fairer, safer, and crime-free,” Rhodes commented.

Joining the responsible gambling conversation was also Louie French, Conservative Party MP and Shadow Minister for Culture, Media and Sport, who said: “I’m backing the Safer Gambling Week campaign to tackle gambling-related harm. This important initiative brings the industry together to support safe and responsible gambling.

“Millions of people safely enjoy a flutter every month, whether it’s on the horses, football, or the lottery. But for some, gambling can cause immense harm to their lives. It’s vital that the industry quickly identifies and supports these people.”

Interestingly, French also made a comment against the widely-speculated gambling tax increases that are expected to be announced with the UK’s new Budget on 26 November.

The public debate has been led by speculations whether Chancellor of the Exchequer Rachel Reeves will increase the duties across the board or leave betting out of the equation.

In his Safer Gambling Week statement, French added: “If the Government taxes people away from regulated bookmakers, they’ll fuel unsafe betting online.”

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Gambling Commission concludes four-part study on black market

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The UK Gambling Commission (UKGC) has published the last out of a part-four series on its approach towards the black market.

While comprehensive, the Yonder Consulting-conducted report did recognise some of the caveats that obstruct the exact estimate of the prominence of the online black market in the UK.

Consumer awareness, drivers, and motivations
To understand the current trends better, the UKGC attempted to first build a profile of the typical black market player with part one of its study, published on 18 September.

With the agreement that it shouldn’t be treated as representative of all those who gamble online, the study outlined four typical characteristics of the users that engage with illegal gambling.

These are generally men, between the age of 18 and 24, who are active gamblers, and who usually rank eight or above on the PGSI problem gambling scale. They typically go to the black market to bet on football, for online bingo, or to play online fruit or slot games.

The motivation behind going out of their way to find illegal sites are most often better odds and offers, games unavailable elsewhere, access to alternative payments like crypto, no stake limits, and a low entry barrier – meaning weak ID or financial checks.

Still, the majority of responses painted illegal gambling as “supplementary rather than exclusive”, meaning people favoured more time and money spent on licensed websites.

Interestingly, however, this seemed to contradict another key highlight – the Commission established that players generally had low levels of awareness of the illegal iGaming market, with responses denying illegal play but indicating differently elsewhere, and vice versa.

Furthermore, only a minority of people was able to name specific black market operators – “numerous” responses named licensed providers as such. Almost all, however, responded that having a licence in the UK is important.

In conclusion, the first part of the Commission’s report found a “disconnect between perceived license importance, understanding if an operator is licensed, and knowledge of how to verify that”.

For the second part of its report, the regulator measured consumers’ rates of engagement with the online black market. Between May 2024 and July 2025, a total of 1,000 unique black market websites were identified, but “no overall increase in engagement in Great Britain”, the Commission stated.

Disruption strategies
Part three highlighted the three tactics that the gambling authority is utilising to hit the black market where it hurts the most. These are Regulation and Investigation (RI), Technological Advances (TA), and Marketing Strategy (MS).

RI includes legal and enforcement measures, such as cross-border collaboration with other institutions, tracking of illegal websites, blocking of such websites, and blocking payments to them, among others.

TA, meanwhile, focuses on eradicating the tools that black market operators are utilising to avoid scrutiny, such as indexing manipulation, VPN use, AI to evade detection, and URL concealment.

Lastly, MS deals with disrupting advertisers and affiliates based in the UK, enforcing advertising standards through the Advertising Standards Authority (ASA), as well as in-depth analysis of SEO marketing.

Estimating the size of the online black market
The latest and final chapter in this four-part study uncovers the three approaches that the UKGC is taking to estimate just how prominent the black market is.

Through the dwell-time approach, the regulator estimates average engagement and time-spent-on-site data – but it largely relies on assumptions, and each additional assumption adds additional margins for error, the UKGC recognised.

The channelisation approach involves comparing engagement rates with the legal and illegal market, but the caveat here is also the need for multiple assumptions.

With the third approach, the UKGC bets on survey-based data. However, this can also often lead to misrepresented assumptions.

All in all, the conclusion was that illegal online gambling is “clandestine” and its exact size often changes and almost always remains in the shadows, with participation rates diluted by a wide range of consumer behaviours.

Reflecting on the latest findings and painting the way forward, Ben Haden, UKGC Director of Research and Statistics, commented: “We have set out areas of work to focus upon. By breaking down the challenge into its constituent parts, it is possible to see a pathway to making an estimate that is fit for purpose.

“Getting there will also need input from operators – data on the legal market will help us strengthen assumptions and update our evidence base. We are looking forward to further conversations to clarify what we need and how operators can help.

“While the exercise of trying to understand the macro-metric of the size of the illegal market is important, the generation of trend data – and insight into specific websites to target disruption activity, is arguably even more vital. We are pleased we are now able to better understand these trends and supply key operational data to our Enforcement Team.”

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SBC Digital Player Protection: Shaping the future of RG

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Join SBC Media on Wednesday, Nov. 12, 2025, as we present the latest iteration of SBC Digital Player Protection in partnership with 1xBet.

The global conversation on safer gambling will take center stage during a full-day digital-only conference dedicated to advancing responsible gaming, regulatory cooperation and player wellbeing across the international betting and gaming landscape. The event will unite regulators, operators, legal experts, academics and thought leaders from around the world to explore how innovation, ethics and regulation can evolve together in the digital age.

Across six key sessions, attendees will gain insight into how technology, collaboration and transparency are shaping the future of responsible gambling.

Session and speakers

Are Stronger Regulations Giving Way to a Stronger Illegal Market?

As governments worldwide impose tighter controls, do stricter rules genuinely strengthen compliance or do they drive players to underground channels? Our panel will ex..

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KSA Chairman: Gambling needs collective accountability to kill black market hydra

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Michel Groothuizen, Chairman of the Kansspelautoriteit (KSA), the Gambling Authority of the Netherlands has declared that illegal gambling is now the principal threat to every regulated jurisdiction.

Speaking at the IAGR 2025 Conference in Toronto, Groothuizen urged regulators to “take ownership” of illegal gambling threats and called for the creation of an Interpol-style international network to coordinate global enforcement and information sharing.
“Illegal gambling is no longer a peripheral problem — it is the principal threat to every regulated market in the world,” he said. “We must act together as if we are the issue owner here.”

A 21st-century battle
Groothuizen described the challenge facing regulators as a technological mismatch between agile criminal networks and slow-moving authorities.

“It feels like we’re fighting a 21st-century war with medieval tech,” IAGR delegates were told. “Bigger and bolder ideas are needed to fight the black market, and that requires a deeper pool of stakeholders with technical expertise.”

He explained that current enforcement tools were designed in an earlier era of gambling regulation, long before the rise of smartphones, crypto transactions and AI-driven marketing — innovations that have transformed how unlicensed operators reach consumers.

“The incredible worldwide rise of smartphones and the incredibly fast growth of technology have made it harder to reach our goals, instead of easier,” he added.

Black Market is never stationary
The KSA Chair said the illegal sector has evolved into a fast-moving global ecosystem that consistently outpaces national law enforcement while threatening consumer safety.

“Illegal operators are innovative and agile. They are our most difficult opponent,” he warned. “We are battling a 21st-century opponent with outdated technology, and that puts us at a natural disadvantage.”

In the Netherlands, the issue has reached critical levels. While over 90% of players still use legal sites, the GGR-based channelisation rate has dropped below 50%, meaning half of all gambling spend now flows to unlicensed operators.

“We warned the government for a tsunami of advertising—and were proved right,” he said. “But if the market gives way to illegal actors, the situation will only worsen.”

He explained that advertising restrictions, while politically popular, have inadvertently pushed consumers towards the very black market the Dutch regime was designed to contain.

Thinking beyond political sensitivities

Groothuizen acknowledged that Dutch policymakers now view gambling as a “high-risk product”, shifting away from the liberalisation agenda that defined the 2021 market opening.

Since 2023, the government has banned celebrity endorsements, outlawed untargeted advertising, and imposed a €700 monthly deposit limit per operator.

“This change of direction is driven by the idea that existing policies do not protect people adequately,” he stated but warned of “ the risk is that overregulation pushes consumers towards unsafe, unaccountable environments—precisely the outcome our laws were designed to prevent.”

He cautioned that the growing compliance burden, combined with declining GGR, has made it harder for licensed firms to compete with unlicensed operators which face none of these constraints.

Though political sensitivities have changed towards gambling since regulation, a complete fallout could be witnessed to the black market.

Big Tech must be engaged
The KSA Chairman stressed that defeating the black market will be impossible without confronting its digital and financial enablers.

“There’s no escaping Big Tech’s involvement,” Groothuizen said. “Social media platforms are the frontline where many consumers encounter illegal gambling for the first time.”

He described how rogue operators buy up expired Dutch web domains — from restaurants and schools to coaches and small businesses — to boost their SEO rankings and funnel users to illegal sites. Influencers, he warned, are being used to promote offshore casinos to young audiences through livestreams.

“Those who do not know that an illegal website exists are not likely to visit it. And those who cannot make a deposit will quickly leave,” he said. “The solution must therefore include the actors who make the market possible in the first place.”

He urged regulators to engage directly with technology platforms and payment providers, or, failing that, push for EU-mandated minimum standards modelled on anti-money-laundering rules.

“We must engage with these parties, but we must also not be afraid to stir things up and act against them ourselves,” he said. “If we do not encounter enough cooperation, then European institutions must step in.”

Towards a Gambling Interpol
Groothuizen’s most ambitious proposal is the formation of a “gambling Interpol” — an international framework through which regulators can share intelligence, coordinate enforcement and apply collective pressure on enablers of the illegal trade.
“Let us put our efforts mainly into a sort of gambling Interpol — first Europe-wide, then perhaps worldwide,” he proposed. “The illegal market knows no borders. Our cooperation should be no different.”

He explained that existing bilateral efforts have proved insufficient. Illegal operators reappear under new domains within hours, nullifying traditional enforcement tactics.

“It’s like battling a Hydra — cut off one head, and two more appear,” he warned.

Groothuizen closed his speech by reframing the fight against illegal gambling as a matter of shared global responsibility rather than national jurisdiction.

“One might wonder who ultimately bears responsibility: the regulators, the politicians, or the big companies in tech and finance that help keep the market running,” he said. “But the fact that there is no clear answer does not absolve us.”

He called on regulators, governments, and industry partners to treat the protection of consumers as a collective moral duty… “Let us all act as if we are the issue owner here,” he concluded.

“Only by taking ownership together can we create an ecosystem capable of protecting players and striking a real blow to the illegal market.”

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South Africa and Nigeria make major AML strides

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Amid ongoing debates over tax policy and regulatory enforcement across Africa’s gambling markets, Nigeria and South Africa reinforced the credibility and stability of their regulated sectors this week.

With regulatory disruptions rife across Africa, the developments in two of the continent’s most significant markets have progressed the legitimacy of gambling across Africa.

South Africa was removed from the AML grey list after originally being added in February of 2023.

In its official announcement, the FATF stated that South Africa strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan.

This included a sustained increase in outbound mutual legal assistance (MLA) requests facilitating ML/TF investigations and asset confiscations aligned with its risk profile.

As well as this, the country took steps to bolster risk-based supervision of DNFBPs (designated non-financial business & professions).

Now that South Africa has been removed from the greylist, the country will have to adhere to stricter stipulations, however. Notably, the sanctions which could be implemented as a result of non-compliance with FATF frameworks have been heightened.

Amongst other issues, there was also a sustained increase in investigations and prosecutions of serious and complex money-laundering and the full range of TF activities aligned with its risk profile.

Nigeria spent the same length of time on the grey list, the country was lauded for demonstrating sustained increases in money laundering investigations and prosecutions, proactive detection of currency declaration violations, and maintained comprehensive data on frozen/seized/confiscated assets.

The South Africa gambling framework is potentially on the cusp of a period of transformation as the country seeks to find balance between enabling growth and ensuring player protection. This has included significant lobbying in the country for a tightening of restrictions on gambling adverts.

Nigeria has also taken steps to significantly tighten the frameworks around its crypto sector tackling the ability of the sector to engage with users in the country.

Discussions over the gambling framework in Nigeria remain prevalent, specifically concerning the impact of Nigeria’s Central Gaming Bill.

Many reports in the country suggest there are fears around the bill diluting the control of the lottery from the state, leading to a petition being put forward pursuing the rejection of the bill.

Pursuit of the rejection of the bill largely comes from the Federation of States Gaming Regulators of Nigeria (FSGRN), underpinning major concerns over the way the establishment of a Central Commission would have on fiscal federalism in Nigeria.

A petition was released aiming to ensure that a central regulator can’t provide state licenses to operators, ensuring that this remains the responsibility of the state.

Nonetheless, the government has continually put forward the case that because iGaming crosses borders this should be the role of a universal operators.

The protection of state revenue is also integral to the bill, with fears it would be lost in the result of the formation of a nationwide commission.

The petition is calling for the nationwide governmental regulation to only oversee the FCT, which is where Abuja is located.

Rallying against the bill, the case has been put forward that it is unconstitutional and simply doesn’t align with the country’s federal system.

However, no matter how fervent and vocal opposition to the bill is, it may well be futile as the Bill has already progressed beyond its third reading in the National Assembly.

There is still a level convolution to its progress though, which will provide state regulators with optimism that it can be halted with enough friction.

Proponents of the bill have argued that it can eradicate growth of illicit operations and boost efficiency within the licensing process.

Mozambique and Burkina Faso were also removed from the list as a result of the steps they have taken to clean their respective frameworks.

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EGBA launches standards for responsible influencer marketing

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The European Gaming and Betting Association (EGBA) has teamed up with the European Advertising Standards Alliance (EASA) to launch a new set of standards for responsible influencer marketing across Europe’s gambling sector.The Pledge on Responsible Influencer Marketing in Online Gambling  is the first industry-wide set of influencer marketing standards in Europe’s gambling sector. EGBA Secretary…

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Interview: 1xBet calls for communication, clarity and consistency from regulators

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As regulated markets become more ubiquitous across the globe, there has been an increased focus on player protection measures. Operators are under more and more pressure to put all guardrails in place to ensure players don’t fall into problematic patterns.

But that is a challenge becoming increasingly difficult without effective and constructive dialogue with regulators, according to 1xBet’s Strategic Advisor, Simon Westbury.

Westbury, speaking exclusively to SBC News at SBC Summit 2025, warned that without open dialogue operators cannot possibly have the clarity or consistency to properly protect players.

He spoke as 1xBet collaborated with SBC Media on a research report on player protection in Western European markets.

“I think what we saw was regulators were viewed more like enforcement agents rather than people you could have a conversation with,” he said. “I’m talking about the three Cs. It was clear that we needed more communication between regulators and operators. Operators are asking for more clarity and also consistency.”

Confusion and uncertainty in western Europe
Some of the findings in the report include that 60% of operators marked the regulation in their primary jurisdiction as seven out of 10, with 43% saying they were unsatisfied, and 26% adding they were worried about the clarity of the information they had.

Some anecdotal data included that some UK operators are nervous to engage with the UKGC, because they didn’t want to look stupid, and Swedish operators looking at how enforcement was done in court cases to understand how the regulations should be applied.

Image: Simon Westbury/1xBet
“I think it’s slightly concerning,” Westbury added. “If we’re the standard bearer in Western Europe for player protection, then we’ve got a lot of work to do.”

Further stats within the body of research included that 30% of respondents said they apply the most stringent regulation if they’re multi-jurisdictional.

Westbury said that this simply isn’t conducive to being a global gambling operator.

“Now that’s mental,” he exclaimed. “In terms of personalisation and localisation for players, you have to suit people individually. Someone in Spain is different from someone in France.”

One consistent theme that Westbury identified was that there are clearly improvements required in operators’ dealings with regulators in most western European markets.

He explained: “I think it’s clear that everyone’s working towards the same goal on player protection, but there’s different rulebooks and different standards.

“Operators are confused and I don’t want to be too critical of regulators, but you can’t have an operator in a highly regulated market scared to engage with the regulator. That doesn’t make any sense to me.”

Who takes responsibility for responsible gambling?
In some quarters, particularly throughout media reports and political lobbies, there are accusations that the gambling industry doesn’t do enough on player protection leaving certain segments of consumers vulnerable to the risks of problem gambling.

When SBC News put the question to Westbury, he didn’t outright refute the claims, but noted that operators cannot be solely responsible for any harm.

“I think sometimes there’s a facade that we’re trying to do enough, but this report actually shows quite clearly there’s some challenges,” he said. “Maybe that isn’t a facade. Maybe we are trying to do everything we can.

“But when you read a regulation that’s written in beautiful legal language and you engage with a regulatory body and they just send you back the guidance, it’s not really helpful. You have to understand these guys are civil servants; they are enacting the regulation, but if it’s not clear, how can you enact it?

“That’s the challenge. It’s not that we’re not doing enough. I think at times we’re trying and failing, but I’m not going to put that on anyone’s responsibility.”

So if there is no responsibility for some of the failings, who should take responsibility for player protection. While a nuanced discussion, Westbury did outline that players cannot be held responsible for addictive personality, whether that is for gambling or alcohol or any other addictive behaviour.

He added that certain regulator actions mean that in certain circumstances they must bear the brunt.

For example, in Spain – one jurisdiction in which 1xBet is licensed – the DGOJ regulator is introducing an algorithm to act as a standardised form of risk detection for problem gambling.

He said: “I think this is why this algorithm that they’ve developed in Spain is going to be very interesting, because the onus really isn’t on the operator, it’s on the regulatory body to develop that algorithm and make that algorithm effective. If the operator has that algorithm and the algorithm doesn’t work, it’s not on the operator. It’s not our algorithm.”

Ultimately, though, Westbury did note that operators must take the majority of the responsibility, adding: “The onus has to be on the operator but the problem is when you put the onus on the operator and the regulations aren’t clear, there becomes a grey area which can be exploited, positively or negatively.”

Measuring responsible gambling efficacy
The conversation turned towards best practices for responsible gambling and while tools like deposit limits and interventions are commonplace, 1xBet’s advisor noted that dialogue between all stakeholders can help improve things even more.

That is why 1xBet decided to publish research – to begin a wider conversation around player protection in western European jurisdictions, often touted as some of the leading lights for responsible gambling measures.

Westbury noted: “We are a global company, but we have to have local specificity and that varies from market to market, because our edges are different, and also the regulations are different. We’re not asking for uniform regulations, but we just need more dialogue.

“I don’t think there is a best standard at the moment. I think this report shows that, and I think that this isn’t a one off that we’re doing.”

Finding best practices also include identifying the measures that are most effective in the player protection sector. But how can the industry actually measure this?

Westbury acknowledged that this can be a difficult task, but he pointed out that ensuring that keeping players in regulated markets can be a good barometer and this is driving 1xBet’s interest in acquiring licences around the world.

“The effectiveness is in identifying problem gamblers at the earliest stage so that nothing gets out of control,” he said. “How successful we are is pretty indeterminable to understand, because if you stop one and you find one problem gambler, that’s a result.

“It’s like everything, you can’t stop everyone and people in this day and age always find a way. That’s where we really need to work as an industry, because the black markets are growing in all countries and when the player goes there, they lose all aspects of protection.”

1xBet’s report into player protection in Western European markets is the first of a series of reports that the operator is producing on player protection in different regions. The company is looking to further its commitment to player protection and hopes that by producing research, it can provide valuable input into the conversation.

“You’re never going to make regulation and player protection sexy, but I think this report is interesting,” he said. “I’m looking forward to our other regional reports because the findings are going to guide where we go as an industry, and actually they give us a platform to elevate our performance as operators and regulators.”

You can download the International Player Safety Index by heading here.

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