Stopping ‘unethical affiliates’

How does the affiliate market mitigate channelling those more at risk through their platforms?

That’s a substantial question and unfortunately, it’s not so much about whether it can be done, it’s more about the incentives involved. Regrettably, gambling addiction is something that unscrupulous businesses can profit from. There will always be unethical affiliates willing to exploit vulnerability for profit. Of course, there are affiliates who can choose to act more responsibly and ensure compliance, avoiding partnerships with illegal operators.

The emergence of various national self-exclusion databases, like GamStop in the UK, has highlighted the extent to which some affiliates are willing to profit from addiction when targeting search terms such as ‘casinos not on GamStop.’ They are fully aware that the individuals generating this traffic are gambling addicts who have registered for a national self-exclusion program. It’s clear that only black-market operators will accept this kind of traffic. Affiliates can act more responsibly by refraining from targeting this type of traffic and not collaborating with partners that accept it.

However, in my opinion, the solution must primarily come from regulation at a higher level. While there are indeed ethical and well-intentioned individuals working in the affiliate sector, there will always be bad actors. If we leave loopholes open, these bad actors will exploit them. We need to collaborate more closely with payment providers to prevent transactions from being processed for these black market operators. Additionally, working with Internet Service Providers (ISPs) to block illegal operators in each jurisdiction is crucial. Until we establish a more robust way to curb the black market, you’ll continue to find affiliates involved in these practices.

Obviously, with the Gambling White Paper coming out recently, the UK Government isn’t about to review its regulations of affiliates soon either...

Personally, I believe that regulators often try to overlook the black market because addressing it is an incredibly challenging task. In reality, the black market has thrived in the US since 2006. Even with the Gambling Commission having dedicated thousands to focus on this issue, it hasn’t made significant progress in curbing the black market. It’s an immense challenge, so there’s a sort of ‘see no evil, hear no evil’ approach.

We’ve recently observed some regulatory authorities reaching out to the charity I founded, BetBlocker, to gather data on the size of the black market. Unfortunately, I think quantifying the black market in this manner is inherently flawed. The black market’s size is somewhat nebulous and it may only represent a small percentage, perhaps 1%, of the overall market. However, if that 1% consists of individuals who are most susceptible to gambling addiction and most severely affected by it, then it’s arguably the most critical segment to address.

In essence, quantifying it to downplay its importance by saying ‘it’s only 1% of the market’ undermines the essential point that it’s the 1% we need to work the hardest to protect. So, I believe we still have a long way to go in effectively addressing the harms caused by the black market. No doubt about it.