
The Gambling Commission is advertising for a Head of Illegal Markets position, ahead of an expected rise in black market activity as a result of regulatory measures.
The British regulator will task the successful applicant with leading high-profile and criminal investigations, providing oversight to the Commission’s illegal markets response, leading on covert surveillance, representing the Commission in judicial proceedings, and contributing to illegal market strategy development, among other duties. They will also coordinate and direct resources from the Commission’s Enforcement and Intelligence functions.
There is a possibility the successful candidate will not be taking the job on a full-time basis. The position is advertised with options for full-time (37 hours per week) and part-time (30 hours per week).
This is despite the Commission stating the successful candidate will play a “critical part in delivering the Commission’s broader strategy to combat illegal gambling, directly contributing to the creation of a safer and more transparent gambling environment.” The reduced working hours and salary of £65,000 per annum could lead to scepticism across the industry about how effective the role could be.
Nigel Harvey, a gambling compliance consultant, wrote on LinkedIn:
“£65k salary just sounds pretty low for such an important position. Illegal markets will grow even more if the FRAs [financial risk assessments] go ahead in the expected form, this is going to be an unbelievably important role - I just can't see how this level of renumeration will attract the calibre of individual needed. Or is that the plan?”
Earlier this week, a macroeconomic study published by the National Institute of Economic and Social Research found measures from the government’s 2023 Gambling White Paper will have a net negative impact of approximately £189 million per year on the wider UK economy, in part driven by greater numbers betting on unlicensed websites.
The study found about 8% of people who regularly gamble reported they would consistently consider visiting unlicensed gambling websites. Close to one third of this group (32.7%) already gamble on unlicensed websites.
When this move to the black market is taken into account, the estimated net negative impact increases to £189 million per year from £134 million per year.
This black market activity is forecast following the implementation of the White Paper. Among the terms recommended were affordability checks (also known as financial risk assessments), in an attempt to protect players spending a certain amount within a certain timeframe, improved identification checks, a statutory levy, and a cap on the maximum stakes on online slots at £5 for older adults and £2 for younger adults.
There is also the potential for black market activity to increase in the wake of increased online taxation. From the start of April, remote gaming duty, paid on online casino bets, was raised from 21% of gross gaming yield (GGY) to 40%.
In addition, general betting duty, paid on online sports bets, will go up from 15% of GGY to 25%; bets on horseracing will be exempt from this.
In April, industry trade body the Betting and Gaming Council (BGC) published the results of a study from YouGov, commissioned by the BGC, showing close to two thirds of bettors would be unwilling to hand over personal documents to operators.
Speaking specifically about affordability checks, BGC CEO Grainne Hurst said at the time:
“These proposals will push customers away from the regulated sector and towards the harmful, illegal black market, undermining the very protections these checks are supposed to deliver.”

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