John Pierce, Gambling Commission Director of Enforcement and Intelligence, has outlined some of the latest developments that the regulator is using in its fight against illegal gambling.
Before joining the Commission, Pierce worked in Trading Standards, which he compares to his current workload.
"The challenges we're now facing are strikingly familiar to those long associated with other illegal markets, such as tackling the importation and sale of counterfeit goods," he explained. "These markets share common traits: complex cross-border supply chains, significant economic harm, consumer detriment, negative impact on legitimate trade and links to organised crime. Investigations are often multi-stranded and present real challenges for an enforcement team to work effectively to co-ordinate action that inevitably crosses borders."
Illegal online platforms, both in gambling and in other industries, are manipulating search engine results, exploiting social media platforms and using trusted payment systems to mimic legitimate businesses and fly under the radar.
To combat this, Pierce explains that the Commission has to continuously develop new tools and teams to evolve alongside the black market.
"Illegal operators are rapidly adapting their tactics, using domain rotation, cloaking and embedding gambling content in unrelated websites. Some sites change their display depending on the device used, while others employ unusual advertising methods such as Google Maps to draw in users," Pierce noted. "These behaviours, while presenting new challenges, indicates that illegal operators are having to adapt their approach in response to our work and our interventions are having some impact."
The Illegal Markets Team has recently gained a new suite of tools to verify which jurisdictions the websites are targeting and assess the illegality of the products on offer.
While it can be difficult to block access to these sites, the Commission is working with payment providers such as Visa, PayPal and Apple Pay to ensure its services are not used for illegal means.
The teams have also "developed referral pathways with major search platforms; Google, Bing, and Yahoo which together account for around 97 per cent of the Internet Search Engine (ISE) market in Great Britain," Pierce continued. "These partnerships enable automatic delisting of illegal content, intelligence sharing and early disruption. While sites often reappear, this remains a valuable tactic."
As for influencer marketing, the Commission has expanded its scope to investigate advertising on social media channels, including Meta, TikTok, X and YouTube.
While British user engagement has fallen 32% on illegal websites recently, the regulator has acknowledged that disruption activity often leads to displacement elsewhere.
Finally, Pierce reflected on which direction the illegal websites may take in the future: "We recognise that the illegal market will continue to evolve, with trends including crypto-based payments, AI-generated branding, copied gaming content and targeted social media promotions. Looking ahead, emerging threats like generative AI, deepfakes and decentralised platforms will require us to further strengthen our technical knowledge and capabilities in future."
While illegal markets may always exist in the shadows, it is reassuring to see regulators taking proactive and effective measures against them all the same.
Pierce concluded: "Dismantling any illegal market is notoriously difficult. It requires joint effort, creative thinking, and an acceptance that no single solution will be sufficient. Given the scale of revenue involved, it's unlikely we will ever fully dismantle the ecosystem surrounding illegal gambling, which is increasingly sophisticated, digitally driven and global in scale."
Pierce has also worked as an Accredited Financial Investigator for the police, Marks & Spencers and UK councils
