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Open Letter to Britain's Technology Platforms: The Illegal Gambling Black Market Is Growing. It's Time to Act.


Dear Leaders of Britain's Tech Platforms,

We are writing to you because a growing threat to consumers is flourishing on your platforms.

Every day, illegal gambling operators use social media, search engines, messaging services and digital advertising networks to reach people in Britain.

They target consumers who have self-excluded from gambling.

They target vulnerable people.

They target those who are looking for help and support.

And too often, they do so in plain sight.

These illegal operators are not part of the regulated gambling industry. They are not licensed by the Gambling Commission. They do not follow British rules. They do not carry out the checks required to protect customers. They do not contribute to research, prevention and treatment. They do not pay UK tax.

Yet they are finding customers through platforms built and operated by you, some of the most sophisticated technology companies in the world.

That should concern all of us.

Earlier this year, Gambling Commission Executive Director Tim Miller delivered a clear challenge to technology companies at ICE, Europe’s largest gambling conference. He highlighted the ease with which illegal gambling advertising, including promotions for so-called "not on GamStop" sites, can still be found online.

He was right.

Consumers who have taken the responsible decision to self-exclude should not be presented with adverts encouraging them back into gambling through unlicensed operators. Vulnerable people should not be targeted by businesses that operate entirely outside the rules designed to keep them safe.

The uncomfortable truth is that this content is still readily available, despite the extraordinary technological capabilities at your disposal.

You have the data.

You have the expertise.

You have the artificial intelligence tools.

You have the ability to identify harmful illegal content at scale.

The issue is no longer whether this problem can be addressed.

The issue is whether enough is being done.

And the stakes could not be higher.

Research by WARC shows that illegal operators now account for almost half of all gambling advertising spend in Britain and could overtake the regulated sector entirely by 2028. Analysis by H2GC forecasts that stakes with black market operators will almost double, growing from £17bn today to £33bn by 2028.

Behind every one of those figures is a consumer being drawn away from the protections of the regulated market and into the hands of illegal operators who answer to nobody.

This is not simply a challenge for the gambling industry.

It is a consumer protection challenge.

It is a public policy challenge.

And it is a challenge for tech platforms.

We recognise that different approaches are required for paid advertising and user-generated content. We recognise that this is a complex and evolving threat.

But complexity cannot become an excuse for inertia.

Some technology companies participate in the Gambling Commission's Illegal Gambling Taskforce. Yet as the black market continues to grow, there remains little visible evidence that collective action is matching the scale of the threat.

Consumers need outcomes, not meetings.

Action, not attendance.

Results, not good intentions.

That is why we are calling on tech platforms to make a renewed commitment to tackling illegal gambling online.

We urge you to:

  • Proactively identify and remove illegal gambling advertising before it reaches consumers.
  • Invest more resources in detecting and disrupting black market operators.
  • Strengthen cooperation with law enforcement, regulators and industry.
  • Share intelligence to prevent illegal operators simply moving between platforms.
  • Publish greater transparency around enforcement activity and outcomes.
  • Join a coordinated effort to keep vulnerable consumers away from unlicensed operators.

This is not a call for confrontation.

It is a call for leadership and collaboration.

The regulated betting and gaming industry, regulators, law enforcement and technology companies all have a role to play. None of us can solve this challenge alone.

But equally, none of us can stand on the sidelines while illegal operators exploit gaps in the system.

The black market is growing.

The threat is real.

The consumers at risk are real.

And the time for action is now.

We stand ready to work with every platform willing to help protect consumers, disrupt illegal operators and ensure the online ecosystem is not used as a gateway to gambling harm.

The question is simple.

Will you join us?

Yours sincerely,

Grainne Hurst

Chief Executive, Betting and Gaming Council

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