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“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.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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The acceptance and authorisation process is restricted to paid media. Regarding organic content that sells, markets, depicts or promotes online gambling, Meta states, in the restricted products and services section, that it encourages safety, prevents potentially harmful activities and displays content only to those over 18 years of age.

The policies in question do not mention the practice of responsible gaming and do not detail other legal and regulatory obligations. They also do not specify the resources used to validate certifications, monitor licences and content, identify irregular practices and operators, or apply moderation measures. 

The absence of governance policies aligned with current regulations and Instagram’s algorithmic recommendations reveals not only an ecosystem that fuels gambling as an alternative to work, but above all, points to a systemic risk in which Meta is a major player. This risk can only be effectively addressed by expanding the obligations of digital platforms.

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Blok called for more decisive immediate action, saying: “The government must act now through criminal prosecutions by the Public Prosecution Service, alongside measures taken by regulators and licensed operators. 

“Tackling illegal gambling requires joint responsibility from banks, payment providers and hosting services who facilitate these platforms.”

The lottery operator also criticised government proposals for a blanket advertising ban on licensed online gambling providers in June. It argued such restrictions could inadvertently drive more players towards unregulated, illegal platforms.