UKGC Study Finds 91% Overlap Between Repeat Illegal Gambling Users and Licensed Sites
An analysis of banking records found that repeated transactions with illegal operators generally accompanied licensed gambling, with no substantial shift away from regulated businesses.

The Gambling Commission has found that 91% of individuals with repeated detected transactions involving illegal gambling operators also used licensed operators.
The finding comes from an analysis of anonymised banking records published on October 28. Researchers identified 3,426 transactions believed to involve illegal operators, linked to 179 people. The 91% figure applies specifically to those with repeated detected transactions, rather than every individual in that group.
Licensed Activity Continued Alongside Illegal Gambling
Researchers examined transaction patterns before and after individuals’ first detected payment involving an illegal operator. They found no substantial shift away from licensed gambling in the following months.
Transactions involving illegal operators frequently appeared in clusters, with several occurring within short periods. Where individuals used both licensed and unlicensed businesses, transactions with the two groups also often occurred close together.
The Commission said these patterns suggest illegal gambling can supplement existing licensed activity. Its accompanying commentary described the findings as consistent with earlier consumer research, while stressing the importance of using multiple sources to understand the illegal market.
Credit Card Transactions Still Detected
Of the identified transactions involving illegal operators, 138, or 4%, used credit card accounts. Fifteen of the 179 individuals had at least one such transaction.
The remaining 3,288 transactions used current accounts. The figures describe detected financial activity and do not establish how much of each person’s total gambling expenditure went to illegal businesses.
Findings Cannot Measure the Whole Illegal Market
The Commission emphasised that the dataset is not nationally representative. Participants had voluntarily shared their banking data for research, and some demographic groups were over-represented or under-represented.
The analysis also excluded cryptocurrency payments and covered only a subset of illegal operators. Transactions with unidentified businesses could therefore have gone undetected, including among people already identified as using unlicensed services.
These limitations mean the research cannot estimate the illegal market’s total size or its share relative to licensed gambling. It also cannot establish whether using illegal operators causes gambling-related harm.
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