Zero. That is the number of gambling regulators anywhere in the world with the legal power to raid an office, seize a server or arrest a director outside their own national borders. Every enforcement tool a national watchdog holds stops at the frontier, while the operators it chases are structured to ignore frontiers entirely. That mismatch is the reason the chair of the Dutch regulator has now put a blunt idea on the table: build an international investigative service.
The proposal: an international investigative service for illegal gambling enforcement
Michel Groothuizen, chair of the Dutch gambling authority Kansspelautoriteit (KSA), argued in comments published in September 2026 that national regulators are increasingly outmatched by the scale and mobility of the illegal gambling market, and that international collaboration is no longer optional. His specific suggestion is the creation of an international investigative service dedicated to illegal gambling enforcement, rather than leaving each authority to fight the same offshore operators alone from inside its own jurisdiction.
The framing matters. This is not a call for a single global gambling licence or a world regulator that overrides national law. Licensing, tax and product rules would stay national. What Groothuizen is describing is the investigative layer, the part of the job that involves finding out who actually runs a website, where the money goes, and which corporate shells sit in between. That work is where national mandates hit a wall fastest.
Coming from the KSA, the intervention carries weight. The Netherlands opened a licensed online market in October 2021 and has since been one of Europe’s more active enforcers, issuing penalties against unlicensed sites aimed at Dutch players. Even a regulator with that track record is saying, in effect, that the current toolkit does not scale.
Why national regulators keep losing the cross-border fight
Illegal gambling is not a local business with an international side effect. It is an international business that treats each national market as a customer segment. Cross-border cooperation is needed because the offence, the evidence and the assets almost never sit in the same country.
Jurisdictional walls that operators plan around
A typical unlicensed operation targeting a regulated market might hold a light-touch licence in one jurisdiction, incorporate in a second, host infrastructure in a third, process payments through intermediaries in a fourth, and market through affiliates in a fifth. None of those choices is accidental. They are designed so that any single regulator can only ever see one fragment of the structure, and can only compel disclosure from entities inside its own reach.
The practical consequence is familiar to anyone who follows enforcement notices. A regulator identifies a site, establishes that it accepts local players, imposes a fine, and then discovers that the company named in the decision has no local assets, no local directors and no intention of paying. The site reappears within days under a new domain, sometimes with the same payment rails and the same affiliate network. Regulatory compliance costs the licensed operator down the road real money; for the unlicensed one it is a branding exercise.
Where today’s enforcement tools run out of road
Most authorities rely on a fairly standard set of measures. Each does something useful. Each also has a point at which it stops working against a determined cross-border operator.
| Enforcement tool | What it is meant to do | Where it breaks down |
|---|---|---|
| Fines and sanction decisions | Penalise operators serving players without a local licence | Collection depends on assets or cooperation in the operator’s home jurisdiction |
| Website and IP blocking | Cut off access for local players | Mirror domains, app stores and VPN use restore access quickly |
| Payment blocking | Stop deposits and withdrawals reaching unlicensed sites | Intermediaries, crypto and misdescribed merchant codes route around it |
| Advertising and affiliate action | Remove the marketing that drives traffic | Affiliates and influencers often sit outside the regulator’s jurisdiction |
| Criminal referral | Bring prosecutions against the people behind the operation | Requires identifying real beneficial owners abroad and slow mutual legal assistance |
Read the right-hand column together and the diagnosis is clear: the bottleneck is rarely willingness to act. It is evidence and reach.
How a shared investigative service would work in practice
Neither the KSA nor anyone else has published a detailed blueprint, so the honest answer on mechanics is that the design is still an argument, not a statute. But the functions such a body would need are not mysterious, because equivalent structures already exist in other fields of financial and consumer crime.
- A shared intelligence picture. A single place where gambling authorities deposit and query data on domains, corporate entities, beneficial owners, payment processors and affiliate networks, so that one regulator’s dead end becomes another’s lead.
- Joint case teams. Investigators seconded from national authorities working one target across several markets at once, instead of five parallel files that never meet.
- Coordinated action dates. Blocking orders, payment instructions and public warnings landing on the same day in multiple countries, which is far harder to route around than a staggered sequence.
- Standardised evidence. Common formats for test purchases, screenshots and transaction records so material gathered in one jurisdiction is usable in another’s proceedings.
- A single point of contact for third parties. Payment providers, hosting companies, app stores and search platforms currently field inconsistent requests from dozens of authorities; one credible interlocutor changes the response time.
Gambling watchdog cooperation on this level would still sit on top of national law. An international team could establish who runs a rogue casino and how the money moves; the decision to fine, block or prosecute would remain with each member authority. That is both the design’s strength and its ceiling.
Sizing the black market betting problem honestly
What is actually known about unlicensed operations
Be sceptical of any single headline figure. Estimates of black market betting volume vary enormously between studies because the methods differ: some count traffic to unlicensed domains, some survey players, some model the gap between expected and licensed turnover. Industry-funded and regulator-funded research routinely reach different conclusions, and neither can observe the market directly. What is not seriously disputed is the direction of travel, which is why several European regulators, including the KSA, publish channelisation targets and treat the unlicensed share as a core performance measure rather than a footnote.
The structural point stands regardless of the number. Unlicensed operators have no wagering audit, no funded player protection programme, no contribution to treatment services and no tax liability in the market they sell into. They can therefore outspend and out-promote licensed rivals on the same players. Each market that tightens its licensed rules without matching enforcement hands that gap a little more room.
What players actually lose
For a player, the difference between a licensed and an unlicensed site is not a technicality. It is the entire list of things you can fall back on when something goes wrong:
- No enforceable payout. If an unlicensed operator voids a win, cites an obscure term or simply stops responding, there is no regulator with jurisdiction to compel payment.
- No independent game testing. Licensed markets require RNG and RTP verification by accredited labs. Off-market, the stated return to player is an unverified claim, and the house edge could be anything.
- No complaints route. No adjudication body, no dispute deadline, no appeal.
- Exposed data and money. Identity documents and payment credentials handed to an entity you cannot locate, sometimes recycled through processors that mislabel transactions.
- Safer gambling tools that are optional or fake. Deposit limits, cool-off periods, reality checks and self-exclusion are licence conditions in regulated markets. On unlicensed sites they may be absent, or reversible on request by the operator that profits from you continuing.
Indian readers have a particular reason to follow this. Enforcement here already leans on the same blunt instruments described above: website blocking by central authorities, advertising restrictions, and state-level prohibition laws, layered on top of the central Promotion and Regulation of Online Gaming Act, 2025, which prohibits online money gaming services. Those measures act on access and marketing rather than on the corporate structures behind offshore sites. Nothing in India’s toolkit reaches a beneficial owner in another hemisphere, which is precisely the gap Groothuizen is describing.
What coordinated enforcement would change for player protection
Better player protection from this proposal would come from unglamorous plumbing rather than dramatic takedowns. Three effects matter most.
First, speed. If the same operator is recognised simultaneously in eight markets, the window between a site launching and being flagged, blocked and payment-restricted shrinks. Most consumer harm from rogue casinos happens in that window.
Second, identification. Shared work on beneficial ownership makes it harder for the same people to relaunch under a new brand, which is the single most common outcome of isolated national action today. Naming individuals rather than shells is also what makes licence refusals in other markets stick.
Third, redress. Cross-border investigation that traces where player funds actually went creates at least the possibility of recovery or coordinated warning, instead of a notice telling players their money is gone. It also gives licensed operators a fairer field: the compliance cost they carry stops being a competitive penalty when unlicensed rivals face a real chance of consequence.
None of this makes gambling safe or profitable. Every licensed game still carries a built-in house edge, and enforcement changes who you are dealing with, not the mathematics of the product. If your play is causing financial or emotional strain, use deposit and loss limits, take a cool-off period, or self-exclude, and seek support from a recognised helpline.
How the rest of the industry is likely to respond
Expect broad verbal agreement and slow practical movement. Regulators have cooperated informally for years through memoranda of understanding and bodies such as the International Association of Gaming Regulators and, in Europe, the Gaming Regulators European Forum. Those channels are good at sharing practice and bad at running operations, because they have no investigators, no budget for casework and no mandate to act.
The sticking points are predictable. Who funds a standing service, and in what proportion? Which jurisdictions are admitted, given that some of the licensing regimes used by offshore operators would be asked to police their own customers? How is data shared across differing privacy and criminal-procedure rules? And what happens when one member’s illegal operator is another member’s licensee, as is routinely the case in markets with contested legal status?
Licensed industry bodies have a clear incentive to back the idea and will likely couple their support to arguments about channelisation and advertising rules. Consumer and harm-reduction groups tend to welcome enforcement while warning that it is no substitute for affordability checks and product limits in the licensed market. Realistically, the near-term outcome is incremental: more bilateral information sharing, more joint blocking actions, perhaps a pilot task force on a single operator group. A permanent international investigative service, if it happens at all, will arrive as the formalisation of work that has already proved itself case by case.
Common questions
What is international gambling enforcement?
It is the coordinated pursuit of gambling operators who serve players in a country without holding that country’s licence, using tools and evidence that span more than one jurisdiction. Today it happens through cooperation agreements between national regulators; the KSA proposal would add a dedicated investigative service with shared casework.
How does cross-border gambling regulation work now?
Each country licenses and polices its own market. When an operator based abroad targets local players, the regulator typically issues warnings and fines, orders website or payment blocking, pursues advertisers and affiliates, and where possible asks the operator’s home authority for help. Enforcement against the company itself depends on that foreign authority’s willingness and speed.
Why do regulators need international cooperation?
Because the evidence, the assets and the people behind an unlicensed site usually sit outside the regulator’s jurisdiction. Without cooperation, an authority can restrict local access but cannot identify beneficial owners, trace funds or stop the same operators relaunching under new domains.
Does a fine mean an illegal operator has stopped?
Not necessarily. Sanction decisions against offshore operators are often unpaid and frequently followed by a mirror site. That gap between a penalty on paper and a change on the ground is the core argument for the proposal.
For the Dutch regulator’s own publications and enforcement decisions, see the Kansspelautoriteit. Players aged 18 and over only; gamble only with money you can afford to lose.