The Black Market Uncovered: A study on the scale and nature of the UK-facing illicit online gambling market

Session Title

Gambling & Mental Health Crises

Presentation Type

Paper Presentation

Start Date

27-5-2026 12:00 AM

Abstract

Unlicensed online gambling operators increasingly target consumers across jurisdictions using digitally native promotion and automated infrastructure designed to evade detection and disruption. Our work will demonstrate the scale of the UK-facing illicit online gambling market and develop a grounded understanding of how unlicensed operators, often across multiple jurisdictions, acquire and convert players. Scale and scope will be established through a combination of complementary methods, including advanced web intelligence to identify unlicensed operators and map their distribution pathways, alongside structured testing of illicit gambling products to observe the end-to-end consumer journey. Product testing will be used to evaluate potential consumer harms and to compare key features against norms within the regulated sector, including the design and presentation of offers and promotions, payment and payout mechanisms, and withdrawal journeys. The technical monitoring component will examine: (i) the nature of promotional incentives used to drive conversion, including bonuses and “free bet” style offers and how wagering conditions are framed; (ii) the role of affiliate networks, review/aggregation sites, and redirect chains in scaling reach; and (iii) the extent of automation and site proliferation, including rapid replication and domain cycling, and how these tactics interact with common disruption measures.

Author Bios

Charlie is a Director at Alvarez & Marsal. He consults exclusively for the betting and gaming sector and has done so for the last 9 years, specialising in regulatory compliance, strategy and operations. He works regularly with B2C and B2B operators, trade bodies and regulators, with global coverage but a focus in Europe and North America. He speaks at conferences on topics ranging from the customer journey to AML and has peer-reviewed academic research.

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May 27th, 12:00 AM

The Black Market Uncovered: A study on the scale and nature of the UK-facing illicit online gambling market

Unlicensed online gambling operators increasingly target consumers across jurisdictions using digitally native promotion and automated infrastructure designed to evade detection and disruption. Our work will demonstrate the scale of the UK-facing illicit online gambling market and develop a grounded understanding of how unlicensed operators, often across multiple jurisdictions, acquire and convert players. Scale and scope will be established through a combination of complementary methods, including advanced web intelligence to identify unlicensed operators and map their distribution pathways, alongside structured testing of illicit gambling products to observe the end-to-end consumer journey. Product testing will be used to evaluate potential consumer harms and to compare key features against norms within the regulated sector, including the design and presentation of offers and promotions, payment and payout mechanisms, and withdrawal journeys. The technical monitoring component will examine: (i) the nature of promotional incentives used to drive conversion, including bonuses and “free bet” style offers and how wagering conditions are framed; (ii) the role of affiliate networks, review/aggregation sites, and redirect chains in scaling reach; and (iii) the extent of automation and site proliferation, including rapid replication and domain cycling, and how these tactics interact with common disruption measures.