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In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.

Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation. 

This points to a wider shift towards addressing organic search signals and domain-level practices such as doorway pages, an issue also raised in the UK, where research has linked black market migration to search-driven promotion and SEO exploitation.

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“The time was right to reassess this crucial policy area, focusing on the topic of gambling advertising where the former committee’s strong recommendations have been largely unaddressed and where substantial developments in the gambling advertising landscape since 2020 have demanded a re-evaluation of the policy options,” he said.

The committee has advocated for applying a public health framework to gambling advertising regulation. It criticised the existing patchwork of self-regulation, noting the Advertising Standards Authority (ASA) codes, co-regulation for broadcasts and industry-led voluntary measures, were inadequate.

Instead, the report recommended that advertising regulation be placed on a statutory footing under the Gambling Commission.