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Since then, annual advertising expenditure by licensed operators has grown substantially and is now estimated to be between £1 billion and £2 billion, accoridng to , the report said.
According to the committee, robust evidence now links gambling advertising to increased participation and associated harms.
Committee Chair Lord Ponsonby of Shulbrede highlighted that, since 2020, the growth of online marketing techniques and associated harms have shifted the debate substantially.
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AI is used, but only towards the end of the process. First, the system gathers objective indicators; AI is then used to assess the overall pattern and probability of a connection. “We only provide evidence-based findings,” Madsen says. “We don’t say that something is a mirror site because we suspect it is. It is only reported when we are 100% confident there is a match.”
The timing is significant. The illegal gambling market is attracting growing attention from regulators and the wider industry, while estimates of its size vary considerably depending on definitions and methodology.
A recent Fincord Intelligence report highlighted by the Betting and Gaming Council estimated that illegal online gambling generated around $50 billion in gross revenue globally in 2025. It estimated that around 5,000 operator structures were using more than 15,000 websites and apps.
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The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.
“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”
Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.
