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Peddling Gambling to Addicts

Posted by THEPOGG on Sep 11, 2019

Are you the type of person who sees other peoples’ addiction as a great way to make money? Do you see nothing wrong with ruining lives and exploiting human misery and suffering? If yes, then you are probably the type of human filth that has surfaced in recent months in the online gambling market.

Affiliates Targeting Gambling Addicts

So what’s been going on? A small group of affiliates have struck upon the enlightened marketing strategy of trying to generate traffic by ensuring they rank highly in the search engines for terms like ‘casinos not on Gamstop’.

Gamstop is a UKGC led Responsible Gambling initiative, a national self-exclusion register, intended to allow players who feel that gambling is negatively impacting their lives to exclude themselves from all UK licensed operators with a single request.

Anyone searching for a term like ‘non-Gamstop Casinos’ is highly likely to be both registered with Gamstop due to historic addiction issues and relapsing as they are searching for a way round the exclusion.

Where commercial entities specifically try to profit from assisting addicts in getting another ‘fix’ of the very thing that is ruining their lives, they have crossed an ethical line that in our mind makes them irredeemable. These are people with no moral conscience what-so-ever. Happy to ruin another life to enrich themselves.

You can find a full discussion of this issue on Casinomeister –

How have the industry responded to this issue?

For the most part the operators we have contacted have responded in a clear and authoritative manner, closing the accounts of those affiliates identified as having engaged in this practice. Unfortunately this response has not been universal.

Some operators have, in relation to one specific offending site, looked to make mealy mouthed excuses for the affiliate involved in these practices. The responses we’ve heard from those programs that have tried to dance round the issue and find grounds to continue a commercial relationship with these affiliates have ranged from “they’ve removed the content and apologised” to “it’s not illegal”.

These weak coverings on self-interest are obvious in their duplicitous nature. It does not take any great intellect to take these arguments apart.

Apologies and Excuses

If I find an unconscious girl at a party and decide to take advantage of her, does apologising afterwards make everything okay? If I mug someone in the street, does giving them back their wallet and saying ‘sorry’ get me off the hook? While saying sorry may be taken into consideration in any subsequent judgement of my actions, it is highly unlikely to result in my actions being disregard and the harm I’ve done to those involved trivialised.

Removing the content and apologising does not change the business practices these affiliates have engaged in, the precedent they have set in terms of the strategies they are willing to engage to generate profit, nor does it undo the harm they have done to the users they pulled into their pages by targeting these search terms.

Beyond this – while some of these affiliates may have removed the offending content (though not all), for the most part they continue to work with the same unlicensed, rogue operators that they were trying to channel this traffic through to in the first place. The same operators who have rap sheets as long as any operator in the industry and who are widely blacklisted due to their mistreatment of players. But of course, these affiliates are genuinely sorry for what they have done. It has all been a terrible misunderstanding and they have changed their errant ways. These type of statements are what the rolleyes emoticon was invented for.

As to the legality of these activities, in the first instance arguing that anything that is not illegal is by default morally acceptable is a contemptible argument that merits no response. The argument also does not bear scrutiny. Where an operator accepts UK players without a UK license, they are breaking UK law. Where their affiliate partners are actively facilitating this, looking to drive UK traffic to unlicensed operators and profiting off this traffic, they are unquestionably facilitating actions that are in breach of the law.

Further to this, whether or not the practice actually qualifies as ‘illegal’, UK licensed operators are subject to the UKGC’s Social Responsibility Code, which includes “children and other vulnerable persons should be protected from harm or exploitation from gambling.” This practice is very clearly both harmful to and exploitation of those persons vulnerable from gambling.

Money, money, money

So if the justifications for continuing to work with these affiliates are self-evidently weak, why are any operators making them? The answer is straight forward – money.

We have recently looked to bring on board a Search Engine Optimisation (SEO) service to help us improve the rankings of ThePOGG. We spoke to several major firms in the sector over the course of August and part of the pitch that we ordinarily received usually included a basic SEO audit of our site including comparison to highly visible competitors in the sector. One name kept popping-up on these lists:

With a cursory glance down that list it is easy to see that one name jumps out as having engaged in exploitation of gambling addicts and who continue to work with rogue operators.

So is it reasonable to conclude that it just so happens that we are getting push back from some operators who are listed on this particular offending site because they genuinely do not see the problem here? Or is it more likely that, given the high visibility of this particular site in the search engines, that this site is generating traffic volumes for these operators that they simply do not want to give up?

In our opinion the answer is obvious. That does not make it any less distasteful to see these programs prioritise money over protecting vulnerable players.

What happens now?

Up till now ThePOGG has only contacted programs we work with about this issue. As we previously mentioned the response has been very positive for the most part. As of today we will be contacting all operators that we identify on these sites and informing them that if they continue to work with these affiliates as of the beginning of October – providing ample time for action to be taken – we will be moving their review status to Blacklisted, and including information highlighting their willingness to cooperate with and support advertising partners who have looked to directly target and exploit gambling addicts.

This practice is totally unacceptable and we want no relationship with any gambling operator who would try to excuse these actions simply to line their own pockets. Beyond this, we would suggest that if as an operator your brand ends up on an affiliate site’s ‘top’ list parked beside some of the most disreputable operators in the industry you may perhaps want to question whether your position there is any accolade and whether or not the placement reflects poorly on your brand.

Come October we will also be looking to draw the focus of the UKGC to this issue.


For all operators – we would strongly recommend considering the product that Rightlander offer. Their service includes monitoring of the SERPs for sites appearing in searches related to ‘not on Gamstop casinos’ to help you keep ahead of which affiliate partners are exposing you to risk with amoral advertising practices.

Rightlander had this to say about their latest update:

“Rightlander checks affiliate pages and social media pages for compliance issues on behalf of approximately 100 brands and we provide a range of standard reports which can each be customised to cater for the interpretations of compliance guidelines by each operator. One of these reports specifically looks for content that might deliberately be aimed at vulnerable individuals and contains hundreds of variations of different phrases and combinations of words which the system is programmed to consider as unethical , deceptive or exploitative. Ultimately the operator makes the decision as to whether the content reported from this report constitutes non-compliant marketing materials and they are also responsible for taking the appropriate action.

The report is constantly being redefined and in August, we added the most recent set of words and phrases which were mostly centred around the promotion of betting operators who accept UK players and do not integrate with the Gamstop service. The first reports from this were delivered to operators on Monday 2nd September and the report is now an integral part of the Rightlander scans.


Rightlander is a web content compliance monitoring solution which is designed to help operators and affiliates work together in regulated jurisdictions. Our remit is to provide data to operators which they can then use to descriptively inform and educate affiliates of changes that they need to make in order to remain compliant within that jurisdiction.

With operators often responsible for ensuring their affiliate’s content is compliant and due to the obvious risks this poses to both an operator’s licence and the viability of their affiliate program, many operators have historically avoided risking it all by either putting affiliate accounts on hold until manual compliance checks can be carried out or by removing potentially risky affiliates or those affiliates whose content cannot be easily reviewed. Rightlander scanning now ensures that content can be monitored quickly and regularly and also means affiliates with accessible content do not find their accounts suspended for long periods while they wait for a manual check to take place.”

You can find out more about this tool at

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The United Kingdom of Great Britain and Northern Ireland sits to the north-west of mainland Europe. The United Kingdom shares a border with The Republic of Ireland and has coasts on the Atlantic Ocean, Celtic Sea, North Sea, Irish Sea and English Channel. The population of the UK is approaching the 67.6 million mark leading to a fairly densely populated land mass. The gambling sector in the United Kingdom is entirely regulated and licensed by the UKGC – the United Kingdom Gambling Commission. Should players resident In the UK wish to gamble with foreign based operators there is no history of this being treated as a criminal offence, but high levels of protection exist for UK residents playing with UK licensed operators.


The above information is what we believe to be the the legal status of online gambling, however information on this topic is limited and hard to find. We accept no liability for any errors or ommissions. It is the reader’s responsibility to ensure that they know the legality of online gambling in their country before engaging with any online gambling service.