Picture an analyst at a national gambling regulator opening a case file on one unlicensed betting site. The domain is registered through a privacy proxy. The hosting sits in one country, the company on the footer is incorporated in a second, the licence it claims comes from a third, deposits route through a payment processor in a fourth, and the traffic arrives from affiliates and Telegram channels spread across a fifth. The regulator’s legal powers stop at its own border. Everything that matters about the operation sits outside it.
That mismatch is the whole argument behind the latest push on international illegal gambling. Michel Groothuizen, chair of the Dutch regulator Kansspelautoriteit, has called for the creation of an international investigative service to go after illegal gambling, arguing that national regulators are increasingly outmatched by operators that treat borders as a routing problem rather than a limit.
What the Dutch regulator is actually asking for
The proposal, as reported by Focus Gaming News, is for something with investigative teeth rather than another forum for exchanging views. Groothuizen’s position is that the scale of the illegal market cannot be addressed by a single authority acting alone, and that cooperation needs to move from information sharing to joint action.
That distinction is the point. Cross-border channels already exist. Regulators sign bilateral memoranda of understanding, meet through bodies such as the Gaming Regulators European Forum and the International Association of Gaming Regulators, and swap intelligence on problem operators. What they do not have is a shared body that can open a case, gather admissible evidence across several countries and hand a prosecutable package to whichever authority has jurisdiction. Every regulator builds its own file, from scratch, on the same handful of networks.
Anyone who has watched the Kansspelautoriteit work through its enforcement list will recognise the frustration. The Dutch regulator has been among the more active in Europe on unlicensed supply, and it still ends up chasing brands that reappear on a new domain within days.
Why international illegal gambling is so hard to police
The structural problem is that an illegal gambling operation is modular. Take away one component and it is replaced, usually cheaply. A blocked domain becomes a mirror. A dropped payment provider becomes a crypto rail or a network of mule accounts. A named company gets dissolved and the brand carries on under a new corporate shell.
Meanwhile the regulator chasing it is bound by national administrative law, national evidence standards, and a budget approved by a national parliament that expects results inside its own market. Fines issued against an offshore entity with no local assets are often uncollectable. The enforcement asymmetry is not a matter of competence. It is a matter of geography.
How a cross-border case moves, step by step
If you want to judge whether a shared investigative service would help, it is worth following the actual sequence a case goes through. Each step is where the process either advances or dies.
- Detection. Complaints, player reports, affiliate monitoring, ad surveillance and mystery shopping flag a site accepting customers it should not be accepting.
- Attribution. The regulator tries to establish who is behind the brand: corporate records, domain history, payment counterparties, platform and game supplier fingerprints.
- Jurisdictional test. Is the operator actually targeting this market? Local language, local payment methods, local currency and local marketing are the usual triggers.
- Evidence gathering. Screenshots, transaction records, test deposits, terms and conditions, marketing material, all packaged to a standard that will survive a legal challenge.
- Action. Cease-and-desist orders, fines and penalty payments, plus indirect levers where they are available: payment blocking, domain blocking, app store and search delisting, pressure on suppliers and affiliates.
- Follow-through. Collecting the fine, monitoring for mirror sites, and deciding whether to escalate to criminal authorities where fraud or money laundering is involved.
The first two steps are duplicated in every country a network touches. Steps five and six are where a national regulator runs out of reach.
| Stage | Where it stalls today | What a shared investigative service could add |
|---|---|---|
| Detection | Each regulator monitors its own market in isolation | A common intelligence picture of networks active in several markets at once |
| Attribution | Ownership hidden behind proxies and shells in other jurisdictions | Pooled corporate, domain and payment data so one entity maps the whole structure |
| Evidence | Files built separately, to different national standards | Joint casework designed to be usable by more than one authority |
| Action | Orders and fines unenforceable against offshore entities | Coordinated, simultaneous pressure on domains, payments, suppliers and marketing |
| Follow-through | Mirror sites and rebrands reset the clock | Persistent tracking of networks rather than one-off action against brands |
What such a service could realistically do, and what it could not
Realistically, a joint unit would be an intelligence and casework body, not a police force. It could hold a shared register of illegal operators and the people behind them, run coordinated investigations, standardise evidence formats and act as the single point of contact for payment networks, hosting providers, app stores and ad platforms. That last function alone would matter: private gatekeepers respond faster to one credible, well-documented request than to eleven partial ones.
What it could not do is create powers that member states have not granted. There is no international gambling law to enforce. Conduct that is criminal in one market is licensed in another, and several jurisdictions actively host operators that their neighbours consider illegal. Any body like this depends on voluntary cooperation, sustained funding, and members willing to act on findings that are commercially inconvenient. Those are the three things international initiatives usually run short of.
Expect the debate to run through the existing regulator cooperation channels first, and expect the hard questions to be about money and mandate rather than principle.
What it means in practice
For licensed operators, the calculation is straightforward. Channelisation is the argument the industry uses to resist tighter rules on advertising, deposit limits and affordability checks, and it only holds if the illegal alternative is genuinely being suppressed. More effective cross-border gambling enforcement strengthens that argument. It also raises the compliance floor: coordinated investigations tend to follow the money and the supply chain, which means platform providers, game studios, payment processors and affiliates should assume their counterparty checks will come under sharper scrutiny than before.
Affiliates in particular should read this as a warning. Marketing is the cheapest part of an illegal operation to disrupt and the easiest to attribute. If you are pushing traffic to brands whose licensing status you have not verified in the market where the traffic originates, you are the visible end of someone else’s problem.
For players, the practical stakes have nothing to do with regulatory politics. Unlicensed betting sites sit outside the systems that exist to protect you: no enforceable deposit or loss limits, no access to a national self-exclusion register such as the Dutch Cruks, no independent testing of RNG outcomes or published RTP, and no dispute route when a withdrawal is refused. A licensed site still has a house edge and you should still expect to lose money over time. An unlicensed one adds the risk that the game itself, and your balance, are whatever the operator says they are.
Market integrity is the thread running through all of it. Illegal supply distorts competition, undermines match-fixing and anti-money-laundering reporting, and leaves the licensed sector paying for protections that its unlicensed rivals ignore. Whether or not an international investigative service ever gets built, the diagnosis behind it is hard to dispute: enforcement that stops at a border is not really enforcement at all.
If gambling has stopped being entertainment for you, set deposit and loss limits, use cool-off or self-exclusion tools, and contact a national support service in your country.
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