Entain’s International Compliance Director, Joseph Attard, spoke to iGaming Expert about the rise of prediction markets, the challenges posed by the black market and the pathway operators need to take to improve collaboration with governments and regulators.
What avenue do regulated operators have to fight the black market?
The most effective lever is payment enforcement. Blocking card processing and payment services cuts off illegal operators at their most critical point and is far harder to evade than measures like IP blocking.
Beyond that, licensed operators can support regulators by sharing intelligence, commissioning independent research to quantify harm and publicly calling out those who enable illegal gambling.
High-profile interventions, such as our Chief Executive Officer Stella David’s recent open letter to Premier League CEO Richard Masters about the prevalent unlicensed sponsorships among their clubs, help reframe the issue as one of consumer protection and integrity rather than industry competition. Ultimately, enforcement efforts are most effective when they focus on where the risk of harm is greatest.
How can licensed operators do more to celebrate the benefits of playing within the regulated market?
The regulated industry could do a better job at explaining its protections to consumers. Measures like intervention teams, deposit limits, ID checks and exclusion schemes are substantial, but largely invisible to the public. For example, at Entain, we have a team of 460 customer protection specialists and carry out over 12,000 safer gambling interactions a week.
Operators need to explain in simple terms what a licence actually delivers for players and why it matters. As illegal gambling continues to grow, many consumers still don’t understand the risks of using unlicensed sites. There is a strong case for collective public‑education campaigns that clearly set out the difference between regulated and unregulated play, rather than leaving that distinction implicit.
What aspects of an operator’s product offering become less competitive as operating costs rise?
As taxes and compliance costs increase, investment is pulled from marketing, sponsorship and product innovation. For example, at Entain, Coral recently ended its long-standing sponsorship of the Coral Cup at the Cheltenham Festival because of the UK tax increases. This reduces brand visibility, makes customer acquisition harder and weakens the regulated offering relative to illegal competitors who face no such costs.
Promotions and rewards are also squeezed, while unlicensed operators can afford to offer higher bonuses, better odds and fewer frictions. Over time, this disproportionately affects features that help keep recreational players engaged, such as personalised offers, live markets and loyalty programmes.
Which markets are exhibiting signs of black-market acceleration due to regulatory decisions and tax changes?
The UK is the most prominent current example. Remote gaming duty has risen to 40%, nearly doubling the effective tax burden on regulated operators, with the timing particularly damaging ahead of the 2026 World Cup. The Netherlands is the standing cautionary tale where the illegal segment’s share of the Dutch market reached approximately 50% following tax increases.
There are multiple markets where channelisation has deteriorated as regulatory friction has increased without corresponding enforcement against unlicensed operators. Brazil is one of those developing concerns. The SPA framework is still bedding in, and the combination of payment restrictions and incomplete enforcement infrastructure creates conditions where unlicensed operators can operate with limited risk.
More broadly, any market where regulatory costs increase sharply without reciprocal enforcement action against the illegal market risks replicating the Dutch pattern.
How can operators do more to foster collaboration with key stakeholders, such as gaming regulators, to effectively battle the rise of the black market?
The most useful thing operators can do is shift from complaint to contribution. We are currently building a regulator playbook and commissioning research to support law enforcement action. That model works because it gives regulators practical tools rather than industry lobbying points.
Operators hold data that regulators don’t: customer behaviour patterns, payment flows, device fingerprinting and affiliate network intelligence. Structuring that into usable intelligence products and proactively sharing it is materially more valuable than participating in roundtables.
Operators should also be more explicit about what enforcement actions they want. Vague asks for ‘stronger tools’ rarely move regulators. Specific asks, such as consistent merchant ID requirements for payment processors or coordinated cross-border data sharing frameworks, give regulators a clear mandate and make follow-up accountability easier. The IBIA model for sports betting integrity is a reasonable template for how collective operator engagement with regulators can work in practice.
What steps is Entain taking to work with stakeholders to fight the black market?
Entain has taken a public stance against unlicensed gambling, including calling for bans on illegal sponsorship and advertising in sport. David’s public letter to Premier League CEO called for an immediate ban on sponsorship and advertising partnerships with unlicensed gambling operators and welcomed the DCMS consultation on a formal ban.
The company is also supporting regulators through research and enforcement toolkits and working through integrity bodies to protect sporting competitions.
How can governments and regulators balance greater regulation and player protection measures without significantly increasing the chance of pushing players towards the black market?
The core discipline is sequencing enforcement alongside regulation. The recurring failure documented across multiple markets is that friction on licensed operators increases before enforcement against unlicensed operators is strengthened, which simply moves customers. The increased black-market activity will lower overall tax revenue, so the fiscal case for effective enforcement is at least as strong as the consumer protection case.
Regulators should also resist treating all regulatory measures as equally beneficial. Some measures, such as affordability frictions and mandatory deposit limits, carry a measurable channelisation risk that needs to be modelled before implementation, not discovered after. The Netherlands and now the UK experience should inform an analytical framework that stress-tests proposed interventions against channelisation risk.
Finally, regulatory resources should be explicitly allocated to enforcement against the illegal market, not just compliance oversight of licensed operators. The Gambling Commission‘s callout of Meta over unlicensed gambling advertising is a model worth replicating because it applies pressure where the distribution infrastructure sits.
How has the rise of prediction markets in the US further blurred the lines between the black market and the regulated sector?
Prediction markets operate with zero safeguards. They sit in a regulatory grey zone, technically not classified as gambling in many US states, but functionally offering betting markets on political outcomes, sports results and geopolitical events. Platforms like Polymarket have run betting markets on events involving Venezuela and Maduro. The problem is that the jurisdictional ambiguity is not accidental.
Prediction market operators actively exploit the gap between securities regulation and gambling regulation. For consumers, the distinction between a prediction market and an offshore sportsbook is meaningless, but the consumer protections are categorically different.
The French regulator has already flagged the risk that prediction markets could incentivise real-world harm, including attempts to influence political outcomes. This blurring weakens the regulated sector’s ability to argue that the licensed/unlicensed distinction maps neatly onto safe/unsafe.
Joseph Attard, International Compliance Director at Entain, will be speaking at the SBC Summit Malta. Get your tickets here.
Affiliates and operators are eligible for complimentary passes.
