BEATING THE BLACK MARKET
Fighting the black market – the infinite game LUIS PORTELA DE CARVALHO AND MARTA BOTICA SANTOS EXPLORE A DIFFERENT APPROACH TO TACKLING UNREGULATED GAMBLING
gambling operators, targeting consumers within the European Union and an approximate percentage of 92% of all gambling- related content seen online by consumers of these states can be linked to unlicensed operators. The magnitude of these figures indicates a substantial expansion of illegal gambling market activity, extending to multiple regulatory and economic dimensions. As unlicensed operators operate outside the mandatory safeguards designed to protect players, this increases players' exposure to risks. Simultaneously, illegal operators compromise the competitive position of licensed operators, whose compliance and fiscal obligations are integral. This article will analyse the evolving landscape of the black market, assessing the effectiveness of measures adopted by regulators across jurisdictions to combat and end the “war” between unregulated and regulated markets. The analysis
Introduction With the rise of the global gambling industry and its constant, rapid evolution in recent years, the expansion of online gambling platforms, driven by technological innovation, has simultaneously fuelled the growth of unregulated markets. The increasing presence of unregulated markets, with an activity that is not supervised by the legal authorities, has become one of the main challenges facing the gambling industry. Recent empirical research reveals the scale of this challenge, exposing the extent to which unregulated operators have invaded regulated markets. According to studies published by Yield Sec on illegal online gambling, unregulated markets accounted for 71% of the European Union's online market in 2024, representing an estimated 80.6 billion in gross gaming revenue 1 and an annual loss of 20 billion in EU tax revenue.
Such research also appoints more than 6.200 active illegal
1 European Casino Association, ‘The European Casino Association releases a Yield Sec report on illegal online gambling, uncovering annual loss of €20 billion of EU tax money’ (European Casino Association, 20 November 2025) https://www.europeancasinoassociation.org/news/ press-releases/the-european-casino-association-releases-a-yield-sec-report-on-illegal-online-gambling-uncovering-annual-loss-of-eur20-bil- lion-of-eu-tax-money?trk=article-ssr-frontend-pulse_little-text-block
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IMGL MAGAZINE | MARCH 2026
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