Affiliates and the Black Market: Rethinking Acquisition in Unlicensed iGaming

Unlicensed iGaming operators rely not just on avoiding regulatory scrutiny, but on their ability to acquire players—often via sophisticated affiliate networks and digital marketing. The sector’s black market acquisition problem is deeply linked to the same affiliates and comparison sites that power legitimate traffic for regulated brands, creating an uneven competitive field and making the task of blocking illegal play increasingly complex.

How Black Market Operators Acquire Players

Regulatory crackdowns often target unlicensed operators directly, working to block their sites, payment channels and advertising. But most illegal operators would not reach customers without efficient acquisition methods. Affiliates—comparison sites, SEO-optimised web pages, social influencers and even streaming personalities—can give black market sites both discoverability and the appearance of credibility. This has particularly acute consequences when users land on these operators through outlets they already trust.

For instance, the Netherlands Gambling Authority (KSA) has investigated affiliate pages that direct players to operators not connected to Cruks, the Dutch self-exclusion register.

"A player who reaches an unlicensed operator through a professional-looking comparison website or a creator they already trust may not even realise they have left the regulated ecosystem." (EGR Intel)

The Uneven Playing Field in Acquisition Channels

Responsible affiliates and licensed operators face strict rules on advertising, player protection, and responsible gambling. Unlicensed operators, however, can operate without those costly restrictions—yet still compete for the same Google searches, social feeds, and audiences as regulated companies.

This imbalance introduces problematic incentives. Black market operators often offer high affiliate commissions and fewer regulatory strings, making it tempting for some acquisition partners to work with them. The regulated sector is tasked with higher compliance burdens while competing for visibility against actors that do not have to play by the same rules.

Why Simply Restricting Affiliates Won’t Work

Some may argue for stricter rules governing affiliates as a solution, but tightening restrictions on the regulated sector does not eliminate the root problem. Growing limitations on how licensed brands and responsible partners acquire users could simply increase the appeal and visibility of their black market counterparts.

The real need is more accountability throughout the acquisition infrastructure. Operators should vet affiliate partners carefully, with due diligence on where traffic originates and monitoring for those directing players to both licensed and unlicensed brands.

Affiliate networks themselves should implement standards for identifying and removing recurring bad actors. Regulators, meanwhile, are encouraged to collaborate more closely with search engines, social platforms, payments providers, and related tech firms to disrupt the acquisition supply chains that enable illegal monetisation.

Technology’s Role in Disrupting Black Market Acquisition

The legal iGaming space already uses advanced technology for attribution, fraud detection, and audience segmentation. These same tools—expanded and fine-tuned—can help:

• Identify suspicious acquisition patterns
• Detect networks of domains funneling users to illegal sites
• Spot affiliates that vanish and resurface under new identities

"Enforcement needs to become as connected and data-driven as the ecosystem it is trying to disrupt." (EGR Intel)

Targeting individual unlicensed brands is insufficient: traffic and attention can simply shift to the next black market site. The only sustainable answer is to undermine the economic and technical means that make illegal acquisition attractive.

Making Accountability Central in Affiliate Marketing

Sustainable affiliate marketing cannot be measured only by volume or immediate conversions. Protecting the ecosystem on which long-term regulated growth depends is equally critical. Licensed operators that want to safeguard their future need to focus on creating, and enforcing, standards and due diligence that remove incentives to compromise on acquisition integrity. In practice, this could mean:

• Ongoing reviews of affiliate traffic sources
• Clear contractual clauses forbidding parallel promotion of illegal brands
• Closer monitoring by affiliate networks, with transparent procedures for delisting violators
• Regulatory coordination with platforms and payment processors to reduce unlicensed visibility

The article highlights insights from André Moreira, founder and CEO of Vexia Group—a media agency specialising in iGaming brand solutions. His company's proprietary brands, LiveSponsors and JogoAJogo, reflect a commitment to strategic, technology-driven acquisition models that emphasise compliance and innovation.

The Path Forward for Regulated Operators and Affiliates

Winning the battle against the black market is not just about enforcement, but about disrupting the structural advantages that drive unlicensed acquisition. As long as illegal operators can buy attention and efficiently acquire traffic, gaps will persist. The industry’s challenge is to protect acquisition integrity with the same rigour it applies to product integrity—a mission that requires every link in the chain, from operator to affiliate network and regulator, to work in concert.