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“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.

According to Nederlandse Loterij, illegal operators currently control approximately half of the Dutch online gambling market and account for roughly 95% of online gambling advertisements, frequently masquerading as licensed providers. 

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In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.

Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation. 

This points to a wider shift towards addressing organic search signals and domain-level practices such as doorway pages, an issue also raised in the UK, where research has linked black market migration to search-driven promotion and SEO exploitation.