When we discuss the growth of illegal igaming, the conversation usually focuses on operators: whether they are licensed (or not), where they operate and what regulators can do to block their websites, payments or advertising. But there is another question we should be asking: how are these operators finding players in the first place?
An unlicensed operator without visibility, traffic or customers has limited reach. To understand why the black market continues to grow, we therefore need to look beyond operators and examine the acquisition infrastructure that supports them. Affiliates are an important part of that equation.
Affiliate marketing itself is not the problem. It remains a legitimate and valuable acquisition channel for the regulated igaming industry, helping consumers discover and compare operators while allowing brands to compete for audiences. The problem begins when the same expertise is used to direct players towards unlicensed platforms.
Search rankings, comparison websites, social media, influencers, streaming and highly optimised content can provide unlicensed operators with something extremely valuable: discoverability. They can also give them credibility. A player who reaches an unlicensed operator through a professional-looking comparison website or a creator they already trust may not even realise they have left the regulated ecosystem.
This is particularly concerning when acquisition strategies deliberately exploit the boundaries of regulation. In the Netherlands, for example, the Netherlands Gambling Authority (KSA) has investigated affiliate websites promoting unlicensed operators, including sites targeting people searching for operators not linked to Cruks, the country’s self-exclusion system. Regulators are increasingly recognising that tackling illegal gambling requires looking not only at supply, but also at the networks that make that supply visible and accessible.
Uneven playing field
There is also a structural imbalance that the regulated industry cannot ignore. Licensed operators, and affiliates working responsibly with them, invest heavily in compliance and operate under rules covering advertising, targeting, player protection and responsible gambling. Unlicensed operators do not necessarily face the same costs or restrictions, yet they can compete for the same Google searches, social feeds and audiences.
This creates a difficult equation. The companies carrying the greatest regulatory burden may find themselves competing for acquisition against businesses that are not playing by the same rules. If an unlicensed operator can offer aggressive affiliate commissions while avoiding many of the obligations imposed on licensed companies, there is a financial incentive for parts of the acquisition ecosystem to direct traffic towards the black market.
The answer, however, cannot simply be more restrictions on legitimate affiliates. This is not an argument against stronger enforcement or proportionate regulation. If regulation makes it increasingly difficult for licensed operators and responsible affiliates to communicate with consumers while unlicensed alternatives remain easily discoverable, we risk creating precisely the conditions in which the black market can gain visibility.
What we need instead is greater accountability across the acquisition chain. Operators should strengthen due diligence around affiliate partnerships, including understanding where traffic originates and whether partners are simultaneously promoting unlicensed brands. Affiliate networks should establish and enforce clearer standards for identifying and removing publishers that repeatedly direct consumers towards illegal operators. Regulators, meanwhile, need closer cooperation with search engines, social platforms, payment providers and technology companies to disrupt the infrastructure that allows those operators to acquire and monetise players.
Technology should also become a bigger part of the solution. Our industry already uses sophisticated tools for attribution, fraud detection, audience segmentation and traffic analysis. Similar capabilities can help identify suspicious acquisition patterns, networks of domains repeatedly redirecting users to illegal platforms and publishers that disappear only to return under different identities.
Enforcement needs to become as connected and data driven as the ecosystem it is trying to disrupt. Ultimately, the fight against the black market will not be won by taking down one unlicensed operator at a time. As long as these operators can efficiently buy attention, generate traffic and acquire players, another brand can replace the one that disappears.
The industry therefore needs to move beyond fighting individual unlicensed operators and focus on disrupting the economics and infrastructure that make illegal acquisition profitable. Affiliates have an important role to play in that transition. Sustainable affiliate marketing cannot be measured only by clicks, conversions or revenue. It also depends on protecting the regulated ecosystem that makes long-term growth possible.
If the legal igaming industry wants to compete effectively with the black market, protecting the integrity of acquisition must become as important as protecting the integrity of the product itself. What would a more accountable acquisition chain look like in practice?
André Moreira is the founder and CEO of media agency Vexia Group and a former professional poker player with over 15 years of experience in the igaming industry. Combining strategic thinking, risk management and technology, he leads Vexia Group in developing innovative solutions for the igaming industry, including the group’s proprietary brands, LiveSponsors and JogoAJogo.
The post The black market has an acquisition problem, and affiliates are part of the equation first appeared on EGR Intel.
Vexia Group CEO André Moreira calls for “greater accountability across the acquisition chain” to disrupt illegal operators and retain players inside the regulated arena
The post The black market has an acquisition problem, and affiliates are part of the equation first appeared on EGR Intel.