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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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The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk.
It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.
Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds.
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The timing is significant. The illegal gambling market is attracting growing attention from regulators and the wider industry, while estimates of its size vary considerably depending on definitions and methodology.
A recent Fincord Intelligence report highlighted by the Betting and Gaming Council estimated that illegal online gambling generated around $50 billion in gross revenue globally in 2025. It estimated that around 5,000 operator structures were using more than 15,000 websites and apps.
Other estimates are considerably higher, illustrating how difficult the market is to measure. As an example, separate research from Gaming Compliance International put the value of unregulated online gambling at $5.9 trillion in wagering value in 2025, while estimating that unregulated operators accounted for 78% of global online gaming GGR.