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The ASA Sanctions an Affiliate for Irresponsible SEO Targeting

The Advertising Standards Authority concludes that Smart Gravity Ltd failed to sufficiently protect vulnerable consumers by displaying a casino comparison ad after the search 'help with gambling'.

By Emilio NavarroPublished Sep 9, 20264 min readEurope
Editorial illustration of a digital ad reviewed by a regulatory authority against a light background

Key Takeaways

  • The ASA sanctioned Smart Gravity Ltd for displaying casino ads to those searching for help with gambling.
  • The investigation revealed that the ad was served through Microsoft Advertising and bypassed the negative keyword filter.
  • The authority concluded that the affiliate's controls were insufficient to protect vulnerable consumers.
  • The ruling requires Smart Gravity to improve its targeting mechanisms in future SEO campaigns.

The United Kingdom's Advertising Standards Authority (ASA) ruled in favor of a complaint against Smart Gravity Ltd, operator of the casino comparison site top10onlinecasinoreviews.co.uk, for lack of control in its online advertising. The case arose from the site appearing in a Google search for the phrase 'help with gambling', questioning whether the ad was irresponsibly targeted at potentially vulnerable individuals.

Smart Gravity Ltd, responsible for campaigns featuring information about operators licensed by the UK Gambling Commission, initiated an internal investigation and determined that the advertisement was served via the Microsoft Advertising platform. According to the company, all its campaigns are directed exclusively at adults in the UK and there are ongoing compliance processes to prevent ads from appearing in inappropriate search queries.

These controls include periodic reviews of campaign settings and targeting, examination of negative keyword lists, and internal compliance monitoring. Smart Gravity emphasized to the ASA that "it has no commercial interest in targeting individuals seeking help for gambling problems" and stated that it does not target ads towards vulnerable consumers, minors, or users interested in self-exclusion or addiction support.

ASA and the Challenge for Responsible Targeting

Despite Smart Gravity providing the ASA with its list of negative keywords—including terms related to gambling addiction, responsible gambling, and gambling-related harm—the authority determined that these controls were insufficient to prevent ads from appearing before users who might be experiencing gambling harm. According to the regulatory authority, "the mechanisms implemented did not provide a sufficiently robust safeguard".

The agency pointed to the broad match options used by the advertiser, which increased the risk of its ads being served after searches related—but not identical—to excluded terms. "We believe that the use of various forms of keyword matching increases the likelihood of contact with consumers who might be seeking help for gambling-related harm," stated the ASA.

"While we recognize that Smart Gravity Ltd operates a negative keyword list aimed at preventing its ads from appearing in searches related to gambling addiction or responsible gambling, the use of broad matching carries a risk of showing ads to potentially vulnerable consumers," the ASA affirmed in its official ruling.

Regulatory Requirements and Consequences for the Affiliate

The ruling explicitly prohibits Smart Gravity from serving ads alongside searches linked to "help with gambling" and reiterates the obligation to target responsibly in search engines. The ASA highlighted:

"Because we believe there is a considerable likelihood that vulnerable consumers received ads promoting casinos after searching for help, we conclude that the ad was not responsibly targeted," according to the final ruling.

The authority demanded immediate changes to the targeting strategy, highlighting the limitations of automated filters in paid advertising platforms. The ruling reinforces that strategies solely focused on negative keyword lists may be insufficient when broad match techniques are employed.

Context: Other Recent Sanctions in Gambling Marketing

This ruling comes after other similar cases in recent months. In July, the ASA also upheld a complaint against BOYLE Sports for an ad deemed irresponsible, published on the Racing Post portal. That same month, the complaint against Mr Vegas regarding a paid ad on Facebook was confirmed, categorized as having strong appeal to those under 18.

The trend reinforces the pressure on affiliates, operators, and technology platforms to refine their controls and prevent the exposure of gambling products to sensitive or undesired audiences. Increasingly rigorous balances are required between marketing strategy and regulatory obligations, especially in search and social media environments.

Implications for the Gambling Industry and Affiliates

The case demonstrates that responsibility for advertising targeting rests with both affiliates and operators, as well as advertising technology providers. The use of broad matching and negative keywords does not guarantee sufficient protection if results are not monitored actively and frequently. Platforms like Microsoft Advertising and Google Ads, as well as their affiliate users, will be under greater scrutiny from the regulatory sector in light of future incidents of exposure to vulnerable consumers.

This case may influence the review of internal policies and the adoption of new control tools, both technical and governance-related, within the United Kingdom's online gambling industry.

Frequently Asked Questions

Why did the ASA sanction Smart Gravity Ltd?

The ASA sanctioned Smart Gravity Ltd because its casino comparison ad appeared in searches like 'help with gambling', exposing the content to potentially vulnerable individuals without sufficient effective controls.

What controls does Smart Gravity implement in its advertising campaigns?

Smart Gravity maintains a compliance framework with periodic reviews, negative keyword lists, and internal monitoring, although the ASA assessed that these mechanisms did not provide adequate protection in this case.

What changes must Smart Gravity make following the sanction?

The ruling requires Smart Gravity to strengthen its targeting methods and ensure that ads do not appear for searches related to help with gambling issues.

What implications does the case have for other affiliates in the sector?

This case underscores that responsibility for targeting lies with affiliates and platforms, and that the use of broad matching and negative keywords must be reviewed to avoid regulatory missteps.

Source: EGR Awards

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asapublicidad-en-juegosafiliadosregulacióncompliance

About the author

Emilio Navarro

Emilio Navarro

Industry Technology Correspondent

Emilio Navarro covers the cross-cutting technology and business of iGaming — platforms, data and AI, compliance tooling, affiliate marketing, financial results, and the stories that fit no single rubric. The reports open with the announcement, cite vendors and figures exactly as published, and keep a healthy distance from press-release language. When a supplier unveils a new engine or the advertising rulebook changes, Emilio Navarro reports what genuinely changes.

More from Emilio Navarro

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