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The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.

“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.

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Çelik said: “If we can eliminate this sector, we will also minimise the funds flowing into the hands of the next criminal organisation.”  

The president of the Turkish Green Crescent Society, Associate Professor Mehmet Dinç, expanded on this point, highlighting the relationship between supply and demand in the fight against illegal betting. 

“In the fight against gambling, combating supply alone is not enough,” he said. “Combating demand alone is not enough; merely shutting down websites is not enough. This is an ecosystem: it starts with advertisements and continues through social media, sporting activities, influencers, games, mobile applications, payment systems, loans, bets, losses, debt and continued betting.”