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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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Ten committee members, spanning the full political spectrum, addressed a number of research papers, sector activity reports and Justice State Secretary KT van Bruggen’s April 2026-dated letter, assessing the risks of gambling, and acknowledging the KSA’s estimation that channelisation had dropped below 50%.
While there were differing views on much of the content, one area in which Dutch MPs were united was the illegal market.
The majority of parties, including those representing the ChristenUnie, PRO and SGP, all voiced their opinions that increased enforcement against black market operators should be carried out.
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The regulator identified six key categories of fraud frequently encountered in online gambling. These included identity fraud, payment fraud and abusive chargebacks. It also covered in-game cheating, money-dumping and sporting event manipulation
For each category, the guide explained pertinent legal provisions and recommended operational actions.
In cases of identity fraud, operators were advised to close accounts upon establishing fraud and to reserve balances when bank account ownership cannot be confirmed.