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“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”
Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.
By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.
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The KVA’s statement mirrors a broader European regulatory trend where authorities are increasingly scrutinising how major internet platforms facilitate traffic to unlicensed gambling services.
In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.
Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation.
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“This successful investigation clearly demonstrates the scale that the illegal gambling market has now reached,” said Mathias Dahms, president of the DSWV.
Dahms highlighted the significant dangers unlicensed operators pose to player protection and the overall integrity of the licensed market. He cited the absence of controls such as deposit limits, identity verification and player suspension tools.
He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”
