Michel Groothuizen: Gambling needs collective accountability to kill black market hydra

Michel Groothuizen, Chairman of the Kansspelautoriteit (KSA), the Gambling Authority of the Netherlands has declared that illegal gambling is now the principal threat to every regulated jurisdiction.

Speaking at the IAGR 2025 Conference in Toronto, Groothuizen urged regulators to “take ownership” of illegal gambling threats and called for the creation of an Interpol-style international network to coordinate global enforcement and information sharing.
“Illegal gambling is no longer a peripheral problem — it is the principal threat to every regulated market in the world,” he said. “We must act together as if we are the issue owner here.”

A 21st-century battle

Groothuizen described the challenge facing regulators as a technological mismatch between agile criminal networks and slow-moving authorities.

“It feels like we’re fighting a 21st-century war with medieval tech,” IAGR delegates were told. “Bigger and bolder ideas are needed to fight the black market, and that requires a deeper pool of stakeholders with technical expertise.”

He explained that current enforcement tools were designed in an earlier era of gambling regulation, long before the rise of smartphones, crypto transactions and AI-driven marketing — innovations that have transformed how unlicensed operators reach consumers.

“The incredible worldwide rise of smartphones and the incredibly fast growth of technology have made it harder to reach our goals, instead of easier,” he added.

Black Market is never stationary 

The KSA Chair said the illegal sector has evolved into a fast-moving global ecosystem that consistently outpaces national law enforcement while threatening consumer safety.

“Illegal operators are innovative and agile. They are our most difficult opponent,” he warned. “We are battling a 21st-century opponent with outdated technology, and that puts us at a natural disadvantage.”

In the Netherlands, the issue has reached critical levels. While over 90% of players still use legal sites, the GGR-based channelisation rate has dropped below 50%, meaning half of all gambling spend now flows to unlicensed operators.

“We warned the government for a tsunami of advertising—and were proved right,” he said. “But if the market gives way to illegal actors, the situation will only worsen.”

He explained that advertising restrictions, while politically popular, have inadvertently pushed consumers towards the very black market the Dutch regime was designed to contain.

Thinking beyond political sensitivities 

Groothuizen acknowledged that Dutch policymakers now view gambling as a “high-risk product”, shifting away from the liberalisation agenda that defined the 2021 market opening.

Since 2023, the government has banned celebrity endorsements, outlawed untargeted advertising, and imposed a €700 monthly deposit limit per operator.

“This change of direction is driven by the idea that existing policies do not protect people adequately,” he stated but warned of “ the risk is that overregulation pushes consumers towards unsafe, unaccountable environments—precisely the outcome our laws were designed to prevent.”

He cautioned that the growing compliance burden, combined with declining GGR, has made it harder for licensed firms to compete with unlicensed operators which face none of these constraints. 

Though political sensitivities have changed towards gambling since regulation, a complete fallout could be witnessed to the black market. 

Big Tech must be engaged

The KSA Chairman stressed that defeating the black market will be impossible without confronting its digital and financial enablers. 

“There’s no escaping Big Tech’s involvement,” Groothuizen said. “Social media platforms are the frontline where many consumers encounter illegal gambling for the first time.”

He described how rogue operators buy up expired Dutch web domains — from restaurants and schools to coaches and small businesses — to boost their SEO rankings and funnel users to illegal sites. Influencers, he warned, are being used to promote offshore casinos to young audiences through livestreams.

“Those who do not know that an illegal website exists are not likely to visit it. And those who cannot make a deposit will quickly leave,” he said. “The solution must therefore include the actors who make the market possible in the first place.”

He urged regulators to engage directly with technology platforms and payment providers, or, failing that, push for EU-mandated minimum standards modelled on anti-money-laundering rules.

“We must engage with these parties, but we must also not be afraid to stir things up and act against them ourselves,” he said. “If we do not encounter enough cooperation, then European institutions must step in.”

Towards a Gambling Interpol

Groothuizen’s most ambitious proposal is the formation of a “gambling Interpol” — an international framework through which regulators can share intelligence, coordinate enforcement and apply collective pressure on enablers of the illegal trade.

“Let us put our efforts mainly into a sort of gambling Interpol — first Europe-wide, then perhaps worldwide,” he proposed. “The illegal market knows no borders. Our cooperation should be no different.”

He explained that existing bilateral efforts have proved insufficient. Illegal operators reappear under new domains within hours, nullifying traditional enforcement tactics.

“It’s like battling a Hydra — cut off one head, and two more appear,” he warned.

Groothuizen closed his speech by reframing the fight against illegal gambling as a matter of shared global responsibility rather than national jurisdiction.

“One might wonder who ultimately bears responsibility: the regulators, the politicians, or the big companies in tech and finance that help keep the market running,” he said. “But the fact that there is no clear answer does not absolve us.”

He called on regulators, governments, and industry partners to treat the protection of consumers as a collective moral duty… “Let us all act as if we are the issue owner here,” he concluded. 

“Only by taking ownership together can we create an ecosystem capable of protecting players and striking a real blow to the illegal market.”