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Other clubs that hold agreements with unlicensed operators include Chelsea (8XBet), Tottenham Hotspur (VSBet) and Nottingham Forest (FUN88).

Entain highlighted data from H2 Gambling Capital that warned black market stakes in the UK are expected to nearly double from £17 billion ($22.7 billion) in 2025 to over £33 billion by 2028.

Entain emphasised offshore operators do not employ the same player protection measures and anti-money laundering standards that licensed companies must.

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By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

Much of the onus for the increasing black market is put on increasingly restrictive policies enforced by regulators across the licensed sector.

Taking a deeper look at these restrictive driving black market activity, up to 46% of the markets covered in the report enforced “significant advertising restrictions” on the regulated market, including in Belgium, Bulgaria, Coratia, Cyprus, Germany, Italy, Latvia, Lithuania, Montenegro, the Netherlands, Poland, Romania and Spain.

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For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.

The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.

Operators were encouraged to take several practical steps, including enhancing terms and conditions, maintaining robust evidence and uptaking technical standards.