INFLUENCER MARKETING
course organized by LOTBA (covering the legal framework for gambling in the city, the harms associated with unlicensed platforms, and the mechanisms available to players to verify whether a platform is authorized) and, most significantly, to produce and publish a series of videos on their own social media accounts. Those videos were not generic disclaimers. They required the influencers to speak directly to their own audiences (the very same audiences they had previously used to recruit gamblers toward illegal platforms) about the specific problems caused by illegal online gambling, such as the absence of consumer protections, the impossibility of auditing game outcomes, the lack of age verification and the exposure of children and adolescents to unregulated gambling, and the risks of gambling addiction, including its particular prevalence among younger users. The conceptual logic of this approach deserves to be stated clearly, as it is what makes it genuinely novel. The harm caused by the influencer's promotional activity was not merely economic; it was communicational. They had used a powerful channel of social influence, built on personal trust and audience loyalty, to normalize and facilitate illegal gambling. The reparation required them to use that same channel, that same trust, and that same reach, to deliver the opposite message. The instrument of harm became the instrument of remedy. This is a form of restorative justice calibrated to the specific nature of digital harm, and it would not have been available without the criminal framework that made the investigation possible in the first place. Criminal Accountability in Context: A Comparative Note The regulation of influencer marketing in gambling has become a critical issue in multiple jurisdictions in recent
years, and it is useful to contextualize Argentina's approach within that broader picture 10 . In most jurisdictions, influencers who promote gambling – whether licensed or unlicensed – face administrative or regulatory consequences: fines from advertising standards bodies, warnings from gambling regulators, or content removal orders. Norway offers an instructive example of how far administrative tools can reach: the Norwegian Gaming Authority successfully disrupted an entire influencer collective promoting legal gambling platforms through a single regulatory notice, which led to the voluntary shutdown of their operation within hours 11 . The efficiency of that outcome, however, was possible precisely because the influencers involved were operating in a regulated context and had reputational incentives to comply. The illegal market offers no such leverage. Other jurisdictions have pursued the illegal market at the platform level rather than the individual level. The United Kingdom's Gambling Commission removed more than 95,000 illegal gambling websites in 2024 through partnerships with internet service providers and search engines 12 . Denmark's gambling authority entered a formal cooperation agreement with Twitch (the live-streaming platform that has become a primary vector for gambling promotion directed at younger audiences) to restrict the promotion of unlicensed platforms on the service 13 . These are efficient tools for reducing the visibility of the illegal market. However, they address the channels through which illegal recruitment occurs, not the individuals who animate those channels or the structures those individuals operate. An unlicensed platform blocked on one domain or one platform can resurface elsewhere within hours. France has gone further, criminalizing the promotional activity itself: legislation passed in 2023 makes it a criminal offense, carrying up to two years' imprisonment and a EUR
10 Luis Portela de Carvalho, ‘Influencer marketing in gambling and gaming,’ IMGL Magazine Vol. 3. No. 3 (July 2023); Phil Savage, ‘Regulating influencer marketing in gaming and gambling,’ IMGL Magazine Vol. 5 No. 4 (December 2025) 11 Savage, op. cit
12 Portela de Carvalho and Botica Santos, op. cit 13 Portela de Carvalho and Botica Santos, op. cit
IMGL MAGAZINE | JUNE 2026
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