Illegal gambling is booming; Europe must act 

The chairman of the Kansspelautoriteit, Michel Groothuizen, believes that the resources of a national regulator are no longer sufficient to tackle international operators who rely on social media, search engines and financial networks to reach players. 

A battle that has become too big for a single regulator 

The problem now goes far beyond the mere presence of a few unauthorised websites on the internet. According to Michel Groothuizen, illegal operators operate in an international environment: their legal structures, financial flows, advertising and the digital services on which they rely may fall under the jurisdiction of several countries. This structure considerably complicates the work of national authorities. Even when a regulator identifies an operator and imposes a sanction, it must still determine who is actually behind the site, where the company is based and how to enforce the decision. 

The Ksa chairman therefore considers the notion that a properly regulated legal market and a powerful national regulator could, on their own, solve the problem to be insufficient. 

In the Netherlands, half of all money wagered is believed to go to the illegal sector 

To gauge the scale of the phenomenon, Michel Groothuizen cites a particularly worrying figure: according to him, for every euro wagered by a Dutch gambler, half goes to the illegal market. 

He also describes the global illegal gambling market as an industry whose turnover is said to exceed the gross domestic product of every country except the United States and China. 

On the one hand, there are authorities whose powers are essentially national. On the other, there are operators capable of moving their activities, companies and infrastructure from one jurisdiction to another. 

Moreover, the problem is not limited to public revenue. Michel Groothuizen estimates that the failure of illegal operators to pay taxes represents a loss of more than half a billion in the Netherlands. However, in his view, this loss of revenue is not even the most serious consequence. 

Vulnerable gamblers directly targeted 

The crux of his concern relates to the protection of individuals. 

Illegal companies do not comply with the obligations imposed on licensed operators and take no responsibility towards gamblers. 

In particular, the Ksa recently reported a website advertising gambling whilst posing as ‘113.nl’, the Dutch suicide prevention helpline. 

Michel Groothuizen also states that a large proportion of illegal operators actively target people who are already experiencing gambling-related problems and who have registered with the Dutch exclusion register, known as Cruks. The message sent to these players effectively encourages them to circumvent their voluntary ban in order to continue gambling on unauthorised platforms. 

Hefty fines, but difficult to enforce 

In response to these practices, the authorities have, amongst other things, financial penalties at their disposal. However, their effectiveness is hampered by the very structure of the black market. 

Michel Groothuizen explains that fines of up to tens of millions are imposed. Yet these sums remain small compared to the taxes on profits that the companies concerned would have had to pay had they operated legally. 

Above all, imposing a legal penalty on a company does not necessarily mean that the money can be recovered. The operators in question can quickly change their legal structure. Some are based in territories where the scope for intervention by a Dutch authority is very limited. The chairman of the regulator specifically cites the Comoros. 

As a result, even when a company’s identity and location are known, actually enforcing payment of a fine can prove extremely difficult. 

Cutting off visibility and financial channels 

An illegal gambling site needs to be found. It must also allow players to deposit money and, where applicable, to withdraw their winnings. 

It is on these two points that the Dutch authority is seeking to take action. 

It aims to make illegal platforms less visible and harder to find. In particular, the regulator is monitoring their presence on social media and calling on major tech companies to fulfil their responsibilities. The aim is to ensure that digital platforms and search engines do not act as conduits for these activities. 

At the same time, discussions are underway with the financial sector to create barriers to payments. Michel Groothuizen sums up the issue simply: if a player cannot deposit money or withdraw their winnings, the very appeal of the game quickly disappears. 

This strategy therefore amounts to targeting the intermediaries essential to the functioning of the illegal market, rather than relying solely on sanctions imposed directly on its operators. 

Europe called upon to exert influence against the major platforms 

For Michel Groothuizen, it is precisely at this level that European intervention becomes essential. The Netherlands is too small to exert sufficient pressure on global technology and financial firms on its own. He therefore considers it inevitable to go through Europe to achieve more effective cooperation in the fight against illegal gambling. 

This position is supported by the European Casino Association. Its Secretary-General, Hermann Pamminger, points out that the organisation has been calling for enhanced European cooperation for several years. The association states that it shares information with Members of the European Parliament, the European Commission and EU bodies, including Europol and the Anti-Money Laundering Authority. 

His reasoning echoes that of the Dutch regulator: protecting players requires action capable of tracking operators across borders, tackling their financial networks and taking action against the platforms that provide them with visibility. 

The call was also echoed by Duncan Garvie, founder of BetBlocker. Responding to the proposals for European cooperation, he stated that he fully agreed with this analysis. In his view, taken individually, national regulators are ‘completely overwhelmed’ by both the illegal market and the tech giants that enable it to operate. He believes that a credible response can therefore only be built through cooperative action. 

This convergence between regulators and stakeholders committed to combating gambling-related harm highlights the same difficulty: European administrative borders remain national, whilst a significant part of the digital and financial ecosystem of illegal gambling operates without regard for these borders.