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The report singled out several marketing tactics which had been flagged as particuarly concerning.
The first was direct marketing (emails, texts, push notifications). Citing randomised studies, the committee noted that limiting direct marketing resulted in reduced betting and fewer short-term harms.
Referencing an Australian study on direct marketing and its link to gambling harms, Dr Philip Newall, senior lecturer at the University of Bristol noted that “causality was established by getting a random subset of participants to opt-out of receiving direct marketing offers”.
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Much of the onus for the increasing black market is put on increasingly restrictive policies enforced by regulators across the licensed sector.
Taking a deeper look at these restrictive driving black market activity, up to 46% of the markets covered in the report enforced “significant advertising restrictions” on the regulated market, including in Belgium, Bulgaria, Coratia, Cyprus, Germany, Italy, Latvia, Lithuania, Montenegro, the Netherlands, Poland, Romania and Spain.
Additionally the report cited taxing consumers (in 29% of the 28 markets covered), and banned products (14%), were also propelling growth in illegal gambling. A lack of choice, due to monopolies in place in five markets has also driven the rise.
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Shuffle does not hold a licence to operate in the UK.
Meanwhile, Stake continues to feature on the sleeve of Everton’s kits, despite ceasing operations in the UK in early 2025 amid a Gambling Commission investigation into its advertising.
Other clubs that hold agreements with unlicensed operators include Chelsea (8XBet), Tottenham Hotspur (VSBet) and Nottingham Forest (FUN88).