How Casino Game Providers Can Battle the UK Black Market

Virtually every country in the world has some kind of gambling black market. It is a serious problem in both the countries that actually have legal online casinos, and those in which these are banned, and any country that sits anywhere in the middle – with partially approved or semi-legalized online gambling industries. There are many ways for a gambling authority or government agency to go about cracking down on the black market.

And one way is through the game suppliers. Of course, game suppliers run the companies, far from it, but the biggest ones do have considerable influence in these networks. The recent case of Evolution getting fined by the UK Gambling Commission over its games featuring in non regulated sites cast a light on this particular sphere of interest. And while not a direct means to hit the black market, there is a logic in getting the game suppliers on board to help battle these illegal operators.

Efforts to Combat Black Market

Gambling legislation all over the world has tightened considerably in the past couple of years. Regulators have used a range of measures to target the black market, severing ties between it and players.

• Blocking the domains
• Blocking unregulated payment methods
• Gambling ad bans
• Deregistering the site domains from search engines

In Europe, there was a cross border alliance made last year to share data between regulators, helping them to identify these illegal domains quicker and take action. But operators with blocked domains can simply set up new sites (skin sites with different names/slight rebranding), they can also look for alternative payment merchants outside the blocks, and advertising can still be managed through a number of ways. For instance, advertising through social media influencers, setting up gambling ads on illegal live streams (which are being targeted by the UKGC now), and via various other new player recruitment features outside the norm.

But when the Gambling Commission turned their attention to Evolution Gaming, they cast light on a very different kind of strategy.

Evolution Case with UKGC

The UK regulator’s case against Evolution ended with the game supplier agreeing to pay £4.75 million to the Gambling Commission. The crux of the matter was two operators, who had a collective 6 gaming sites that were offering Evolution games to UK customers, but without a UKGC licence. The UK Gambling Commission published a statement on the matter after it had concluded, identifying the main breaches made by Evolution, and the resulting regulatory settlement.

• A payment of a financial penalty of £4,750,000
• Agreement to vary the operating licence, to attach an additional licence condition requiring an independent audit (within 12 months)
• Agreement to the publication of a statement of facts in relation to the case
• A payment towards the Commission’s costs of investigating the case

After the settlement, Evolution didn’t just receive the fine and do nothing. They immediately blocked the games to UK customers on the sites in question. Evolution also said it terminated its relationship with the two companies. Martin Carlesund, the CEO, said:

“At Evolution, we always want to do what is right, and it is not acceptable that six unlicensed sites offered Evolution content in the regulated UK market. We do not want traffic from unlicensed operators and will always move quickly to address any such situation. We welcome the conclusion of the review and remain focused on continuing to supply our world-leading games to licensed operators in the UK.”

Similarities with the Spribe Case

In October 2025, there was a similar situation where the UKGC suspended the licence of Spribe OÜ. The Commission stated that the suspension was made because Spribe, a game software provider, was found to be hosting activity. And to be able to do this, they needed a Gambling Host (Casino) licence from the UKGC. It basically does not fall into the permissions allowed to a gambling software licensed company.

• Game Host (Casino) Licensees: Providing the technical infrastructure to host and operate casino games on behalf of a B2C gambling operator
• Gambling Software Licensees: Develop, supply and adapt existing gambling software (most commonly games and casino systems)

Software providers are allowed to develop new games for the UK, supply these to licensed operators, and change any of their existing games for the operator. They aren’t allowed to host or operate any casino games. This is something that requires a separate licence, the Gambling Host licence. This failing by Spribe, a supplier that created Aviator and specialises in crash games, had nothing to do with the black market. However, it is another example of a very popular software provider getting targeted by the UKC for noncompliance.

The UK’s Gambling Watchdog is prepared to pull the strings or penalize even the biggest operators.

Process of Making Games for Players

Game developers, especially those like Evolution, Pragmatic Play, Playtech, and other big companies, have considerable influence over the market. Think of the journey that new games take before they arrive in a casino. They are created by the software developer, then passed onto the casino partners (either directly or through aggregators), and then tweaked for that platform (setting RTP, max payouts, etc – casino’s can adjust the mechanical elements and algorithms of games – not the actual rules or design of the game) – and then launched on the casino for the general audience.

There are a few ways about this:

• Game supplier → Agreement with a casino operator → Games launch on casino → Player
• Game supplier → Partnering with multi-brand operators → Games can launch on all casinos in the network → Player
• Game supplier → Aggregator → Games can launch on all casinos using the aggregator → Player

The basic differences here are who the supplier turns to when it tries to get its games out there. Smaller companies may turn to aggregators, who can act as the distribution pipeline for getting casino games into their portfolio. Aggregators can white-label B2C operator licences (but not those for suppliers), and as such, these aggregators have their fingers in many pies. Game developer studios can also be contacted or enter talks with casino operators directly. But, and perhaps this is the best for the studios, they can also look to partner with major gaming conglomerate companies. Think about the likes of Flutter, Evoke or Entain, all of which have several brands and international presences. There is definitely a trend in this kind of game developer networking, and it suits both larger companies and small- to mid-range studios – especially those with very original or exclusive games.

There is also a trend of these casino brands creating their own in-house gaming studios, like Caesars’ Empire Creative in the USA. The more the merrier, and where there are opportunities to seize unique content (perhaps even on the cheap with smaller/lesser known studios), the major companies are looking for two things. To stand out in the tough UK iGaming market, and to cut costs where possible.

How the Suppliers Can Fight the Black Market

Suppliers do have some control in this territory, even if it could potentially be at the expense of some revenue (revenue sourced from those unregulated activities). There is a duty of compliance in the UK, so technically the suppliers must ensure that all their games are only provided through legal channels. But black market operators still manage to somehow get a lot of the top games. This is one of their biggest appeals in the UK, especially if they can source leading games, and even pick games from providers that aren’t legal in the UK.

At the time of writing, the UK has over 400 Gambling Software licensees, many of which are very well known brands. If their games suddenly start drying up at black market sites, it would definitely hurt their appeal, which would be a big win for the UKGC. So exactly how much control do these software companies have? Well, they don’t have full control over what the operators offer, but they can:

• Block their games from certain markets
• Terminate relationships with the operators

The first is very important, as the software provider can literally block British players from accessing its content on the site. The black market casino would still be online, but it wouldn’t have those games. The second is to completely cut off the operator. But this is quite a controversial move. Don’t think of unregulated operators here as being black market sites without any licence at all. They may have licences for other countries, but their services are still available or being accessed by UK gamers.

But at the end of the day, by improving diligence and monitoring the activity of their games, game software providers are doing their best to avoid the backlash of the Gambling Commission and help tidy up the sector. A supplier needs to understand who it is doing business with and, increasingly, where its games are ultimately being distributed. And if they have the proofs they need, they can fully cooperate with the Commission. So they do definitely have control, and could be an important part of the UKGC’s plight to curb the unregulated market.