Doubling Down the Damage: The Prevalence of Fake Games in the UK Black Market

The recent publication of the Betting and Gaming Council’s report on the damage that the black market does to the UK economy has started to shine a much needed light on how illegal online gambling operators are targeting and exploiting vulnerable groups.

Our recent article on CasinoReviews.com highlighted how fake game distributors are facilitating these illegal gambling operators cheating players, further accelerating the gambling harms that these vulnerable groups are exposed to.

But how widespread is the use of fake games? Are all black market gambling operators using cheating games to defraud players? Or is this an irregular occurrence that impacting only a small subset of players playing with the black market?

To answer these questions, our team surveyed various sections of the black market to try and establish how widespread the use of fake games is.

The first section of the black market that our team looked into is the operators being advertised on affiliate sites that are targeting search terms relating to bypassing the UK’s national self-exclusion scheme GAMSTOP.

For this exercise, we looked at the first ten search results that came up in Google for the search term “casinos not on gamstop”. For each of these pages we made a note of each gambling operator advertised on the page, which gambling license they displayed and whether we could state with a high degree of certainty that the games being served by the gambling operator were not the genuine article.

It is interesting to note that a couple of the affiliate sites we reviewed were engaging geo-blocking feature to restrict user accessing from UK IP addresses, with notifications suggesting that if the user was engaging a VPN to access the site from a UK IP address, they should disengage the VPN and reload. What is so insidious about this approach is i) the page is singularly targeted at UK users. GAMSTOP is a uniquely UK service, meaning that the only users searching for terms that would bring up this page are from the UK, and ii) the alert for non-UK users to switch off UK VPNs neatly signposts UK users as to how to bypass the restriction they’ve put in place.

This is an extremely cynical approach to claim that the content of the page is not targeted at UK users, whilst providing content that is only useful to UK users, and taking a nudge and a wink approach to steer UK users as to how to access the content.

The first notable result from our work is the size of the black market. We’re only looking at a small portion of the black market operators that are explicitly targeting gambling addicts and we still identified 178 different casinos being advertised across the ten pages. Whilst we cannot assert that all of these sites are run independently, it is very likely there are portfolios of sites being operated by a smaller number of businesses within this set, that is still a huge number of sites generating profit off of gambling addiction. The diversity of businesses operating under this business model suggests a competitive market that this is being viewed as a highly profitable business model, and consequently is causing substantial social damage.

Next we looked at the diversity of brands on the different pages. Where all these pages marketing the same brands, or where there different brand appearing on each site. Below you can see the results:

We can see from the above that the majority of the operators appearing on the not on GAMSTOP type sites only appear on a handful of the sites we looked at. This suggests that these operator may not be explicitly targeting partnering with these types of affiliates, but have been included incidentally because they accept UK players without a license.

However, there is a clear group (appearing on 5+ of these affiliate sites) of 25 core gambling operators that are likely to be specifically seeking out not on GAMSTOP type affiliate partners in an effort to draw in self-excluded gamblers to exploit.

So what else can we find out about this group?

There are certain artifacts that allow us to assert with a high degree of confidence that a gambling operator is deploying at least some non-genuine games. We’re not going to discuss what these artifacts are, as that would make identification of culprits more challenging in future.

We should be clear, the presence of these artifacts makes it likely the operator is distributing fake games. The converse is not true. The lack of these artifacts does not necessarily confirm that the operator is NOT deploying fake games. In fact, for a number of the operators that we have identified as not offering fake games, we have suspicions that the games they are offering are non-genuine based on site design and business profile. We simply lack the high degree of certainty that the identifiable artifacts provide.

As can be seen above, of the 178 gambling operators being advertised on the not on GAMSTOP pages, we identified 128 with the artifacts that indicate that they are deploying fake versions of at least some of their games.

The practical ramifications of this statistic is profound. The only people likely to be searching for terms relating to locating gambling operators that are not part of the GAMSTOP scheme logically are going to be those who have registered with GAMSTOP. These are people who have self-identified as needing support to control their access to gambling. In other word, these are users who are already on the spectrum of gambling harm, and given that they’ve felt the impulse to try and circumnavigate the protections they put in place, it is likely they are towards the more sever end of the harm spectrum.

Marketing gambling to this subset of players is already a highly immoral practice, but our research indicates that over 70% of the gambling operators being advertised on these sites are also using rigged games.

For an ordinary player who is simply engaging in gambling for entertainment, deploying rigged game intended to restrict potential winnings, or accelerate losses, is profoundly unfair and reasonably qualifies as fraud.

Where cheating games are specifically targeted at people vulnerable to gambling addiction, this is likely to substantially accelerate the harm, both financial and psychological, experienced by these players.

This practice is not simply illegal or immoral. It is vindictive and is likely to cause a substantially outsized cost to society for the revenue generated for the business, due to the likelihood that these players could not afford to lose in the first place.

Next, let’s look at who is regulating these black market gambling operator:

As can be seen in the chart above, the vast majority of the gambling operators appearing on ‘not on GAMSTOP’ type sites display no verifiable license information. This means that they either include no information about their license what-so-ever, or they claim a license via text or a seal, but provide no link to a verification page on the regulator’s site.

After this, the largest number of the black market operators appear to be licensed in Curacao, or Curacao associated jurisdictions. The newly formed GCB, Antillephone, one of the soon to be defunct Curacao Master License holder and Anjouan, another island state jurisdiction that has ramped-up efforts to capture some of the gambling operators leaving Curacao due to the change in license. It should be noted that the Anjouan license seal pages are nearly identical in structure and design to those provided by some of the Curacao Master License holders.

How do these figures change when we only looking at the operators we identified as high risk of offering fake games?

When we remove those operators that showed no clear signs indicating that the games they are providing are fake, all of the Kahnawake Gaming Commission operators are removed from the chart.

While Kahnawake still appears to be allowing their licensees to accept UK customers in violation of UK law, the regulator appears to be doing a better job of ensuring its licensees use legitimate and appropriately tested game suppliers.

Other than the removal of Kahnawake, the distributions appear broadly the same.

The second grouping we looked at was slot streamers using the Kick platform. We chose Kick due to a large number of streaming personalities switching to this platform due to Kick offering them higher revenue share deals and looser moderation rules. For these reasons it seemed a reasonable to conclude that we’d find more black market activity on this platform than other similar services.

Unlike the first sample we took, this data set did not focus on users trying to bypass gambling harm minimisation tools, but rather simply looked at the live streams available in the UK where the streamers were playing slots games.

For Kick, we went through every active stream at the time of the survey – midday during the week in the UK – reviewed each active streamer and identified the gambling operator/s that they were advertising.

In total we identified 22 unique gambling operators being advertised, not all of which directly accept UK traffic. However some of those that don’t are known to indirectly encourage players to engage via technological loopholes, turning a blind eye to their advertising partners marketing to UK players and providing walkthroughs on how to bypass geo-restrictions. This was discussed in detail in an article published by Sky News earlier this year.

Again we reviewed the gambling operators that the Kick streamers were promoting to determine whether the artifacts indicating that the games being provided are fake were present.

Whilst we found a significantly lower proportion of the gambling operators advertised by Kick streamers to likely be deploying these fake, rigged, games than the sample of operators advertised on the “not on GAMSTOP” sites, we still found over half of the gambling operator advertised by these streamers to likely be cheating their players with fake games:

The deviation from the proportion of fake game usage we saw on the affiliates marketing “not on GAMSTOP” pages suggests that the different marketing channels have varying appeal to operators that engage rigged games. This could also be associated with licensing, which we will discuss next.

Again we’ll look at the regulators licensing the operators being marketed on Kick:

There are some very pronounced patterns here. Firstly, Curacao licenses represent 82% of all the operators that we saw advertised on Kick.

Secondly operators without any verifiable license information represent a small minority of the market, as opposed to the “not on GAMSTOP” data set, where unlicensed operators made up nearly all of the market.

This could be attributable to Kick itself. The platform my be engaging some degree of oversight and requiring streamers to work with gambling operators that hold a valid license. Or it could indicate that the unlicensed operators find it harder to find streaming partners due to the bigger brand names dominating the market. Or it may be the streamers themselves are doing more to vet their partners.

Regardless of why this is occurring, it is a positive that more licensed operators are dominating this channel and it seems reasonable to suggest that this likely explains why the proportion of fake games we identified was lower.

First and foremost, the prevalence of fake games within the black market was FAR higher than we had anticipated. Whilst our team has been aware of fake games on the market for a number of years, that the majority of unlicensed operators appear to be using fake games emphasises the hidden risk to consumers when they choose to play with the black market.

And the non-uniform distribution of fake game markers we saw across the two verticals strongly suggests that those marketers who are specifically targeting gambling addicts appear to be engaging fake games significantly more often. This may reflect this business model not being as suitable to marketing channels outside of the “not on GAMSTOP” sphere. Or it could represent something far more sinister.

Given that we know that players coming through from “not on GAMSTOP” search terms are almost certainly self-identified gambling addicts, it may be that due to the compulsive behaviours associated with this audience that they are willing to tolerate losing at an accelerated level and continuing to play, where other players exposed to the accelerated loss rates created by cheating games are more inclined to disengage earlier. Or phrased another way, gambling addicts may have a higher tolerance to being cheated.

Regardless of the reasons, this survey has evidenced that the risks to players engaging with the black market are far more substantial than simply lack of the appropriate licensing standards. These illegal businesses are targeting vulnerable user groups and large proportions of them are then deploying cheating software to further exacerbate the harm they cause.