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“What is striking here is the level of activity that apparently failed to trigger effective intervention,” Williams says. “These were obvious indicators requiring further scrutiny, and it is difficult to understand why they did not result in more effective intervention.”

He adds that the recurring weakness is often not an absence of policies but a failure to ensure “technology, algorithms and operational processes actually work in practice”. Some of the QuinnBet issues followed a platform migration, underlining the need to retest controls whenever systems change.

As QuinnBet is also licensed in Gibraltar, Williams expects its regulator to consider the UK’s findings under the jurisdiction’s strengthened Gambling Act 2025. That would not necessarily require a second sanction, but Gibraltar must satisfy itself that any underlying weaknesses have been addressed, he says.

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“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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