BEATING THE BLACK MARKET
from promoting gambling. The Spanish Digital Gaming Association challenged and successfully annulled the law, as the Spanish Supreme Court found it lacked legal basis. Although the reform was not upheld, it illustrates a regulatory approach aimed at addressing gambling-related harm through comprehensive prohibition rather than incremental or adaptive controls. 4 Many jurisdictions have also turned to criminal and administrative enforcement to deter illegal gambling. In the UK, unlicensed gambling can lead to criminal charges, jail time of up to 51 weeks, and fines. These penalties show how seriously illegal gambling is treated, but enforcement remains focused on operators within national borders. Technical enforcement tools, particularly website and domain blocking, have also been widely adopted. In Greece, regulators have registered and blocked approximately 11,000 illegal gambling domains. However, such measures predominantly affect known and existing websites and do not prevent the rapid emergence of new domains operated by the same or related entities. 5 As a result, domain blocking functions primarily as a reactive mechanism targeting individual access points rather than as a comprehensive solution to market-wide illegal activity. Product and operational limits in regulated markets have had indirect effects. Germany’s laws set a €1 maximum bet per online slot spin, require a five-second pause between spins, ban autoplay, and set a €1,000 monthly deposit cap. These rules help protect consumers, but the unregulated market suggests that such limits may drive players to seek out less-restricted sites. Similar trends arise in other Member States. France bans online casino games, leaving players with no legal option for these products. In Portugal, the limited range of legal online gambling leads some players to illegal platforms with more choices. Alongside these national regulations, cross-border regulatory cooperation has gradually increased. Authorities in Austria, France, Germany, Italy, Portugal, Spain, and the United
Kingdom have entered into agreements to address illegal gambling activity together. These initiatives focus on sharing information about unlicensed operators, enforcement, and sanctioning practices. This reflects recognition of the transnational nature of online gambling markets. 6 This coordinated approach has been shaped by reports showing rapid growth in illegal online gambling ads on social media, video content, and affiliate networks. Data showing that more consumers are exposed to unlicensed operators has increased regulatory awareness and triggered calls for greater cooperation. Recent analyses suggest this environment has led to greater scrutiny of marketing, payment flows, and intermediary roles, along with a stronger focus on collaborative enforcement and regulatory information sharing. Does the industry's main challenge demand a change in regulatory mindset? Should regulators embrace the infinite game approach, accepting ongoing adaptation rather than aiming for a single, final victory over the black market? Drawing on the analysis in iGaming Business’s article “Europe’s Illegal Gambling Market: What’s the Solution?” , the persistence and expansion of illegal online gambling highlight that current enforcement strategies are not effective. Reports from February 2023 and later confirm that regulatory action against the black market has produced little change. Data show that unlicensed activity is far more extensive than previously thought. The article highlights that certain regulatory interventions, intended to limit and eliminate illegal markets, have, in practice, contributed to the redirection of consumer demand toward unregulated operators. The tightening of regulatory frameworks through rigid and highly restrictive rules has not demonstrably weakened the structural foundations of the black market. Rather, it has coincided with the emergence of new adaptive mechanisms that enable illegal operators to sustain and expand their presence. The analysis further notes that views remain
4 David Cook, ‘Spain’s Supreme Court Strikes Down Gambling Advertising Restrictions’ (iGaming Business, 10 April 2024) Spain Supreme Court scraps number of gambling ad restrictions 5 Greece blocks 11,000 illegal gambling sites, plans tougher enforcement (Yogonet International, 18 December 2025) https://www.yogonet.com/ international/news/2025/12/18/116890-greece-blocks-11-000-illegal-gambling-sites-plans-tougher-enforcement 6 NEXT.io, Blask x NEXT.io: Which enforcement approaches actually curb offshore gambling? (NEXT.io, 24 December 2025) https://next.io/ news/features/blask-which-enforcement-approaches-curb-offshore-gambling/
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IMGL MAGAZINE | MARCH 2026
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