UK Trade Group Wields Black Market Research From Ukrainian Agency

The UK gambling industry has turned to a Ukrainian consultancy to scope what it says is a $50bn black market that preys on the most vulnerable in society.

Great Britain-based trade group the Betting and Gaming Council (BGC) has revealed findings from a new report which it says shows that the illegal gambling market grossed around $50bn in revenue in 2025.

Operators in the black market are deliberately targeting vulnerable consumers by advertising services as “non-GamStop”, meaning that they are not linked to the UK’s GAMSTOP exclusion register and so can be accessed by people who may otherwise be banned from gambling, the BGC said.

The report, which the trade group has not publicly released, has been compiled by Fincord Intelligence, a consultancy and lobbying firm based in Kyiv, Ukraine.

Fincord is led by managing partner Andrii Yarmolskyi, a former member of Ukraine’s National Security and Defence Council, where he worked on sanctions policy.

Links to Russia

The agency’s new report for the BGC also alleges that black market operators with ties to Russia are being used to evade sanctions.

A number of global powers have escalated sanctions against key Russian individuals ever since the nation invaded Ukraine in 2022.

Fincord’s report has found that businesses associated with the Russian Federation are using cash generated by offering unlicensed online gambling to bolster its war effort.

“Ukrainian authorities assessed that some gambling businesses associated with the Russian Federation may contribute, directly or indirectly, to Russia's economic interests, facilitate sanctions circumvention and create wider national security risks for Ukraine,” said a BGC statement.

The report characterizes these as "analytic assessments rather than judicial findings”.

These operators, say Fincord, exist in a larger global ecosystem of .com operators targeting jurisdictions where they should have a local licence.

Around 5,000 companies are running more than 15,000 websites and apps, with numerous mirror URLs and other block-circumventing tech on hard to dodge any enforcement action, the report says.

"This report shows illegal gambling is no longer simply a regulatory issue. Illegal operators are deliberately targeting vulnerable customers in the UK, including people who have self-excluded, using social media, affiliates and messaging platforms to avoid the protections of the regulated market,” said BGC chief executive, Grainne Hurst.

With black market websites themselves largely well versed in avoiding sanctions, the trade is demanding that officials go after the network of support services that enable these operators to keep trading.

Agencies should target payment services, cryptocurrency intermediaries, affiliates, advertisers, software suppliers and hosting infrastructure, it said.

"The government must step up its efforts to coordinate law enforcement, regulators, payment providers and technology companies to target the networks supporting these operators - not just individual websites," added Hurst.

New tactics needed

The historic approach regulators have taken to pushing back against the black market has been through targeted internet banning orders or issuing fines which are rarely collected and frequently ignored.

Fincord argues that the businesses behind modern-day offshore operators are too sophisticated to stop with this kind of whack-a-mole approach.

"Illegal gambling is no longer a collection of isolated websites. It operates through sophisticated international networks of companies, payment providers, cryptocurrency services, technology platforms and affiliates,” said a spokesperson for the research agency.

Fincord says that around 35% of payments in the illegal sector are now made use crypto, with projections that this could rise to 70% by 2030.

"In Britain, these networks target customers - including people who have self-excluded - through social media, messaging platforms and mirror sites. The Ukraine case demonstrates how the same type of interconnected infrastructure can also create wider financial crime and national security risks,” the Fincord spokesperson said.

"Governments must target the infrastructure that allows these illegal ecosystems to survive, rather than relying solely on blocking individual websites."

Regulators such as the UK Gambling Commission and the Dutch KSA claim to have stepped up their anti-black market activities in recent months, but the industry fears that these continue to grow their footprint.

An apparent lack of success in restricting unlicensed operators from encroaching on the regulated market is a point of particular frustration for operators in both the British and Dutch markets, who find themselves wrestling with tax hikes and tightening regulations at the same moment they claim that the black market is surging.

Even international giants like Bet365 appear to be feeling the effects.

The UK-based operator announced this week that it will cut 340 jobs at its Stoke-on-Trent headquarters and offices in Malta and Gibraltar.

Issues created by increased taxation and regulation were cited among the factors justifying redundancies.