KSA Chair: The Netherlands needs cross-border collaboration to tackle black market

By jili tutorial · September 15, 2026

Cross-Border Collaboration: A Comprehensive Guide to Tackling Europe’s Illegal Gambling Market

Introduction: Why National Efforts Alone Are Not Enough

Michel Groothuizen, Chair of the Netherlands’ gambling regulator (Kansspelautoriteit, or KSA), recently issued a stark warning: illegal gambling is an “unprecedentedly large and complex problem” that no single country can solve alone. In a blog published after the Netherlands’ annual gambling committee debate, Groothuizen highlighted that half of every euro lost by Dutch gamblers flows into the black market. This statistic underscores a broader European crisis — one that demands coordinated international action, not isolated national measures.

This guide expands on the KSA chair’s remarks, providing context, examples, and actionable insights for policymakers, regulators, and industry stakeholders. It explains the scale of the underground gambling economy, the limitations of domestic regulation, the tools being considered in the Netherlands, and the growing push for cross-border collaboration.

The Scale of the Illegal Gambling Problem

Global Revenue That Rivals National Economies

Groothuizen pointed out that the turnover of the global illegal gambling market exceeds the GDP of every country except the United States and China. This comparison makes the challenge’s magnitude clear. Illegal operators often run sophisticated, borderless networks that handle billions of dollars annually, using jurisdictions with weak enforcement to launder money and evade oversight.

In the Netherlands alone, the illegal market captures roughly 50% of all gambling expenditure. That means for every €1 billion legally wagered, another €1 billion is lost to unlicensed sites with no player protections, no responsible gambling tools, and no tax revenue for the state.

The Myth of the “Respectable Foreign Operator”

A common misconception, Groothuizen noted, is that illegal gambling consists of reputable foreign companies that occasionally attract Dutch players through the openness of the internet. “We must abandon that image,” he stressed. In reality, illegal operators are often linked to criminal organisations that run unregulated platforms, use aggressive marketing on social media, and actively target vulnerable populations. These entities are not “grey market” firms waiting for licensing — they are deliberate lawbreakers.

Why National Regulation Falls Short

The Netherlands: A Small Country in a Global Network

The KSA and the Dutch government are “far too small” to tackle this problem alone, according to Groothuizen. While the Netherlands has made progress with its Remote Gaming Act (KOA) — which legalised and regulated online gambling in 2021 — the enforcement of that law remains constrained by national borders. Illegal operators host servers abroad, process payments through international channels, and advertise on platforms based in other jurisdictions.

A national regulator can only do so much: it can revoke licences domestically, issue fines, and block some payment flows, but it cannot subpoena foreign companies or shut down servers in other countries. This asymmetry gives illegal operators a structural advantage.

The Limitations of Unilateral Enforcement Tools

The KSA has deployed several tools within its power, such as ordering payment blockades, issuing public warnings, and conducting undercover investigations. However, the effectiveness of these measures is limited when illegal sites simply move to a new domain or use cryptocurrency for transactions. As Groothuizen explained, “We are fighting a global network of ruthless criminal organisations with dedicated community police officers, whereas we should actually be deploying an international investigative service.”

Current Reforms and Challenges in the Netherlands

The Ongoing Review of the Remote Gaming Act (KOA)

The Netherlands is still implementing reforms to the KOA, as mandated by previous governments. State Secretary of Justice Claudia van Bruggen faced intense questioning from nine Members of Parliament earlier this month on several key issues:

Raising the legal gambling age from 18 to 21 — a measure aimed at improving player protection, particularly among young adults.
Limiting the number of licence holders to reduce market saturation and improve oversight.
An impending advertising ban that would restrict gambling promotions on television, radio, and online.
The black market itself — MPs expressed concern that tighter regulation might drive players to unlicensed sites rather than protect them.

Groothuizen welcomed the parliamentary focus on the black market. He specifically endorsed two proposals:

Developing a tool to block illegal websites — similar to systems used in countries like Australia and Italy, where internet service providers (ISPs) are required to block access to unlicensed gambling domains.
Using fake identities to investigate and catch unlicensed operators — a tactic that enables regulators to pose as players and gather evidence of illegal activity.

Illegal operators have turned social media platforms into their primary advertising channel. Ads for uncredited betting sites appear on Instagram, Facebook, TikTok, and X (formerly Twitter), often targeting users based on location and interests. Groothuizen affirmed that the KSA is “holding the major tech companies accountable,” but admitted that enforcement is slow and inconsistent. Without cooperation from global platforms headquartered in the United States or elsewhere, national regulators are often left issuing takedown requests that are ignored or delayed.

The Case for International Collaboration

Why Europe Must Act Together

Groothuizen’s central argument is that “real impact requires clout at the European level.” He believes it is “naive” to rely solely on a well-regulated national market and a single regulator. The black market’s entire habitat — from financial flows to advertisements — is international. Therefore, the response must be equally borderless.

Key areas where European coordination could make a difference include:

Joint investigative task forces that share intelligence and resources across member states.
Harmonised penalties for illegal operators, preventing them from exploiting differences in national laws.
A unified payment blocking system to cut off financial flows to unlicensed sites.
Common advertising standards that compel social media companies to vet gambling ads at the platform level, not per country.

Recent Developments: FATF and EGBA Join the Call

The KSA is not alone in advocating for international cooperation. The Financial Action Task Force (FATF), the global money-laundering watchdog, recently published “risk indicators” to help regulators identify black-market operators. Its President urged governments to implement “appropriate risk-based responses,” including “public-private collaboration” between regulators and financial institutions.

Similarly, the European Gaming and Betting Association (EGBA) has been vocal about the need for cross-border work. The trade body has set out to improve collaboration with national and international counterparts, sharing best practices and coordinating efforts to shut down illegal platforms.

Challenges to Achieving European-Level Action

Despite growing consensus, several obstacles remain:

Political will — As Groothuizen noted, the Dutch House of Representatives barely mentioned international cooperation during the gambling debate. He regrets that this lack of attention likely means the department will only work on European rules “sporadically,” hidden among other priorities.
Divergent national priorities — Some European countries have stricter gambling laws (e.g., Norway’s state monopoly) while others have more liberal regimes (e.g., Malta). Aligning enforcement tactics can be politically sensitive.
Resource constraints — Smaller European regulators lack the budget and staff to engage in sustained international operations without dedicated EU funding or support from bodies like Europol.

Practical Steps for Policymakers and Regulators

Based on the KSA’s insights and broader industry developments, the following actions can strengthen the fight against the illegal gambling market:

Establish a European-wide blacklist of illegal gambling domains, with automatic blocking by ISPs across member states.
Create a shared intelligence platform where national regulators can report suspicious operators, payment patterns, and advertising campaigns in real time.
Mandate social media screening for gambling ads at the platform level, requiring tech companies to verify the licence status of every advertiser before allowing paid placements.
Coordinate undercover operations across borders, with regulators empowered to use fake identities and digital wallets to infiltrate illegal networks.
Link national AML (anti-money laundering) systems to detect cross-border gambling transactions that may be linked to criminal proceeds.

Conclusion: The Urgency of European Clout

Michel Groothuizen’s message is clear: the illegal gambling market is a sophisticated, global threat that cannot be contained by national regulators alone. While the Netherlands is taking important steps — raising the age limit, considering website blocks, and holding tech platforms accountable — these measures will only go so far without Europe-wide cooperation.

“Their entire habitat is international, from financial flows to advertisements on social media,” he concluded. “Real impact requires clout at the European level. That realisation does not yet seem to be widely shared in the House of Representatives.”

For regulators, operators, and policymakers alike, the path forward lies in breaking down national silos and building a coordinated, Europe-wide response. Only then can the black market’s dominance be truly challenged.