The black market faces an acquisition challenge and affiliates are key

The fundamental issue of the black market's expansion in iGaming lies not only with unlicensed operators but in how they attract new players. While attention is often focused on blocking sites, payments, or ads from illegal operators, the reality is that the acquisition infrastructure, where affiliates play a vital role, continues to provide visibility and traffic to these actors outside the regulated framework.

How Affiliates Facilitate Acquisition in the Black Market

Affiliate marketing remains legitimate and central to the acquisition, comparison, and competition of brands in the legal ecosystem. The challenge arises when this technical and positioning knowledge is leveraged to direct users to unlicensed operators. Currently, methods include SEO positioning, professional comparison portals, content creators, and highly optimized social media strategies.

This makes it easy for the average player to end up on unregulated platforms, often unknowingly, especially if the access is through sites that appear legitimate or sources they already trust. This phenomenon becomes even more concerning in scenarios where advertising or digital presence sits at the fringes of legality, as investigated by the Kansspelautoriteit (KSA) in the Netherlands, detecting affiliate portals that capitalize on explicit searches for operators not adhering to Cruks, the national self-exclusion system.

An Unequal Ground for Legal Operators and Affiliates

The regulated environment requires licensed operators and their affiliates to comply with strict advertising rules, player protection, and responsible gaming, which leads to costs and barriers to entry. In contrast, unlicensed operators evade many of these requirements and restrictions while still accessing the same audience channels, search engines, and social networks as the regulated sector.

This situation creates an imbalance: the more compliant actors may find themselves at a disadvantage against competitors who do not play by the same rules. If an illegal operator offers aggressive affiliate commissions because it lacks regulatory obligations, economic incentives arise for certain acquisition channels to prioritize sending traffic to the black market.

Reinforcing restrictions on legitimate affiliates will not resolve the issue. If regulation makes it difficult for legal brands and responsible affiliates to reach users, while illegal options remain easily visible, the risk of unregulated sector growth increases.

Greater Accountability and Control of the Acquisition Chain

The solution requires a framework of accountability throughout the acquisition chain. On one hand, operators must enhance control and due diligence in their relationships with affiliates, including analyzing the source of traffic and whether any partner also promotes unlicensed sites.

At the same time, affiliate networks need to define and implement clear policies to identify and remove recidivist publishers redirecting users to illegal operators. For regulators, it is imperative to collaborate more closely with search engines, social platforms, payment providers, and technology firms in order to dismantle the infrastructure that facilitates this acquisition and monetization outside the legal ecosystem.

Application of Technology in Monitoring and Control

The legal industry already employs advanced attribution tools, fraud detection, and traffic analysis that can be adapted to identify suspicious patterns, networks of domains repeatedly linked to illegal activity, and publishers reappearing under new identities after being blocked. The enforcement approach must be equally connected and data-driven as the very acquisition ecosystem it seeks to neutralize.

"As long as illegal operators can efficiently buy attention and acquire players, any brand that is removed will be replaced by another," warns André Moreira, founder and CEO of Vexia Group.

Therefore, the industry should not limit itself to blocking individual operators but focus on the economic and technical fundamentals that allow illegal acquisition to remain profitable.

Towards Sustainable Affiliate Marketing in iGaming

The future of affiliate marketing lies in assessing success beyond superficial metrics like clicks or conversions, and incorporating the protection of the regulated ecosystem as a condition for sustainability and real growth. Ultimately, if the legal iGaming industry aspires to compete effectively against the black market, integrity in acquisition processes must be treated with the same priority as the quality of the product itself.

How Could a More Responsible Acquisition Chain Look Like?

According to André Moreira, founder of Vexia Group and with over 15 years in the iGaming sector, striking a balance between strategic thinking, risk management, and technology will be key. Moreira leads the development of innovative solutions at Vexia Group, including the proprietary brands LiveSponsors and JogoAJogo, to help brands and affiliates operate with greater transparency and responsibility.