SBC News

The Advertising Standards Authority (ASA) has upheld a complaint against Hollywoodbets after one of its ads appeared on an esports stats site and was shown to a registered underage user.

What makes this case stand out is that the ad wasn’t placed directly by Hollywoodbets, but by an affiliate marketing partner, which marks one of the few recent rulings where an operator was found to be in breach due to the actions of an affiliate.

About the ad
The banner in question was spotted on www.the-VFL.com, the website of the Virtual Football League (VFL), an EA SPORTS FC esports platform.

Seen on 10 April 2025, the content promoted an offer of ‘UP TO £30 BACK AS FREE BETS + 20 FREE SPINS’ alongside images of athletes from various sports and a call-to-action button reading ‘SIGN HERE’.

It was seen by a 16-year-old user, who had entered their real date of birth when registering on the site. The ASA confirmed the user was logged in when the ad was served, initiating concerns about age-appropriate targeting.

The ad was delivered by Clever Advertising (Playhill Ltd), a third-party affiliate working with Hollywoodbets International UK Ltd.

In its response, Clever Advertising said it had assessed the site as suitable for gambling ads, arguing that VFL.com’s esports content – specifically 11v11 Pro Clubs gameplay – was generally targeted at older players.

The group also pointed to EA Sports FC demographic data suggesting that less than 25% of players were under 18. The ad had reportedly been approved to appear only before users logged in, not during logged-in sessions.

The verdict
Despite the arguments, the ASA upheld the complaint and found the ad had been served inappropriately. The watchdog ruled the ad breached several parts of the CAP Code, including rules designed to prevent gambling ads from being directed at under-18s.

Affiliate marketing plays a significant role in the UK gambling sector, but ASA rulings in recent years have largely focused on ads placed directly by operators.

Hollywoodbets has now confirmed that the ad had been placed by Clever Advertising and said it cooperated fully with the ASA. Meanwhile, The-VFL.com said it had no control over the specific ads served on its site and removed the promotion once the complaint was raised.

Social media crackdown
The ruling comes just a month after the ASA sided with Buzz Bingo following complaints about a Facebook ad, showing the extent of online advertising and the potential pitfalls that can come from this for operators.

The ASA received two complaints concerning a post from the Buzz Bingo Grimsby Facebook page in April, which used an action figure to promote its bingo offering.

The complainants raised concerns that the ad’s design, particularly the use of the action figure, could appeal to children and potentially encourage underage gambling.

The British Home Office has declared that there has been an increase in illegal casinos targeting the UK in its latest National Risk Assessment (NRA).

Citing this and other factors the Home Office has raised the anti-money laundering (AML) from low to medium, though the risk for terrorist financing remains low.

The risk level was maintained at low in the 2017 and 2020 Home Office’s NRAs, but the department has opted to raise it due to a number of changes it has observed over the past five years.

Changes in customer, geographical and transaction risks are the main reasons cited by the Home Office. The government is particularly concerned with the increase in funds moving through online casinos, new ways to play casino games and an updated assessment of casinos as Money Service Businesses (MSBs).

In this latter case, not all casinos function as MSBs and the Home Office has noted that the number of casinos offering services like foreign currency exchanges and cheque cashing services has declined, some still do.

MSB services heighten the money laundering risk faced by UK casinos, the Home Office asserts. The 2025 NRA stresses that MSB services attract higher risk customers using higher risk transactional methods, such as those making transitions to and from high risk jurisdictions.

White labels under spotlight
The connectivity between the UK casino sector and counterpart industries in more high risk financial jurisdictions has been causing a headache for British authorities, and those of other jurisdictions, for some time.

Even more alarming for the government is the alleged connections between some UK casino companies and illegal overseas operations. White label deals have been cited as being of particular concern here.

White label deals are commonplace in the UK, whereby companies pay a white label partner to operate their UK domain for them under said partners’ licence. The Home Office is concerned about some cases where operators have relied on unlicensed third parties for compliance.

“In these cases, the licensee would remain responsible for compliance, although they did not always have sufficient oversight,” the National Risk Assessment details.

“These arrangements are now less common, but risks remain where white-label providers offer large numbers of websites, as failure by a single remote casino to control the ML risks relating to their white-label partnerships can impact a significant number of websites.”

White label deals have been the subject of some negative press over the past couple of years. Much of this publicity has been around Isle of Man-based companies, with TGP Europe in particular getting a lot of attention.

Last year, the licence for TGP Europe-operated Kaiyun Sports expired, leading the UK Gambling Commission (UKGC) warning the company’s then football partners, Nottingham Forest and Crystal Palace, to reconsider the sponsorships.

TGP Europe would later shut down all of its brands in April 2025, surrender its operating licence and have to pay a substantial fine to the Commission, which accused the firm of failing to carry out sufficient due diligence against its partners, among other licensing breaches.

This came after years of mourning concerns at the Isle of Man government around the island’s targeting by international criminal groups. The Crown Dependency’s government shared concerns previously raised by the UN about the extensive activity of East Asian and Southeast Asian illegal gambling and cryptocurrency operations.

The UK Home Office risk assessment has not singled out any particular geographic region. However, the Home Office has noted that Suspicious Activity Reports (SARs) around illegal activity related to casinos have increased from 2020, rising from 6,000 in 2022/23 to 7,500 in 2023/24.

“Illegal casinos continue to attract new customers, heavily targeting online advertising with offers that entice new customers to gamble with them,” the NRA read.

“As they operate illegally, they will not be supervised by the Gambling Commission, nor have a requirement to implement MLR controls. The use of cryptoassets in illegal casinos is also increasing.”

Illegal casinos have been met with regulatory and enforcement action. The report notes that the UKGC issued 1,158 stage one cease and desist notices relating to online casinos, referred 118,181 URLs to Google and Bing and had 81,292 URLs promoting casinos from search engine results between April 2024 and March 2025, for example.

Further challenges are on the horizon though, particularly technological ones. The NRA highlights the use of AI as a key example, with deepfaked documentation commonly used to bypass compliance checks.

The Home Office has also cited the use of in-game currencies as presenting fraud and money laundering risks and crash games being offered by some licensed casinos as presenting a money laundering opportunity for criminals.

The timing of this report is apt, coming at the same time that the licensed betting industry both in the UK and in other European nations continues to make the case that a gambling black market is posing significant risks to regulated gambling sectors.

However, while the NRA has noted the increase in prevalence of illegal gaming, something licensed operators have been highlighting for years, it does also point out some flaws in the regulated industry that operators may want to address if they want their black market concerns to be taken seriously.

The UK Gambling Commission (UKGC) has published the results of an updated exercise which looks at the ongoing impact of policy change related to VIP or High Value Customer (HVC) schemes.

In a blog post, the UKGC’s Head of Evidence Assurance and Evaluation, David Taylor, detailed that such VIP and HVC schemes were “no more commonplace” in 2024 than they were in 2021 after the regulatory change, which changed how an operator can make a customer a VIP so that they wouldn’t be used to exploit gamblers.

Operators can only make customers VIPs now once they have checked that their spending is affordable and sustainable as part of their leisure spend; assessed if there is evidence of gambling-related harm or heightened risk linked to vulnerability; make sure they have up to date identity, occupation and source of funds evidence; and continue to verify information provided and conduct ongoing gambling harm checks on each individual.

Individuals at operators are also made personally accountable for the scheme’s management via a senior executive who holds a personal management licence.

In response to the High Value Customer and VIP Scheme Monitoring Report‘s publication, Taylor noted that the report, based on 2024 data, followed a similar process to the report from 2021, so the results can be considered comparable.

However, it was added that the new report “benefits from the addition of further questions and a consideration of whether HVC or ’VIP’ schemes are referenced in Commission casework”.

Land-based casinos

Alongside the fact that the schemes are no more commonplace than they were previously, the number of people in such schemes has remained consistent, with every HVC scheme having a senior executive appointed to oversee operations as well.

The report also found that HVC schemes were “less often assessed as being a contributory factor in issues under investigation within Commission casework”.

The UKGC calculated the proportion of gross gambling yield which is produced by HVC schemes in the sample as being around 3%.

Yet, there was a significant difference between operators and sectors, with land-based casinos having “a greater reliance on scheme members as a proportion of GGY”.

The Commission did acknowledge that staff supervision and interventions can help provide gambling harm support when necessary, and that the vast majority of customers in high-end casinos are high-net-worth individuals based overseas.

Taylor stated: “This factor, in particular, may have led to the difference in GGY proportions compared to other sectors and it’s worth noting that this finding isn’t accompanied with any allegations of consumer harm, but it is something that can be factored into the Commission’s assessment work.”

Outlook

In his closing comments, Taylor noted that while the intended impact of the VIP and HVC scheme changes is being accomplished, it’s important to remember that the exercise was “reasonably modest in scope”.

“Limitations are detailed in the report and include details about the sample of operators and how this is intended to provide a relatively high-level overview of the policy’s effectiveness. It’s also worth noting that the impact of this policy is also influenced by other changes to regulatory requirements on topics such as customer interaction, for example.”

Taylor concluded that, for now, no additional changes will be made to VIP and HVC schemes, but the UKGC is still ready to step in when required.

“Although evaluation exercises like this will never be able to give total assurance, it does provide an indication that the regulatory objectives have been delivered and further changes are not currently required.

“Where operators fail to meet requirements, we will continue to take action.”