The Dutch Gaming Authority (KSA) has imposed a penalty payment order on Winbet NV for offering unlicensed games of chance. Offering games of chance without the required license is prohibited in the Netherlands. If the party does not cease the violation and keep it ceased, it will be imposed a penalty payment.

Investigation by the KSA has shown that Winbet offered gambling via four websites: galaxyspins.com, winnercasino1.bet, superb1.bet and doctorspins.com. For this, it has been imposed a penalty of €280,000 per week, with a maximum of €840,000.

On all the sites examined it was possible to create a player account, make deposits and participate in the illegal gambling offered. No technical measures were taken on the sites to prevent participation from the Netherlands.

The Netherlands has a regulated gambling market to better protect players. The KSA therefore takes tough action against illegal supply. With an order subject to penalty, illegal supply is often quickly stopped. Providers can also be fined for the period in which the illegal supply was available.

In a massive international operation targeting illegal football gambling and its associated criminal activity, authorities made over 5100 arrests and recovered more than USD 59 million in illicit proceeds.

The operation, code-named SOGA X and conducted between June and July 2024, was a collaborative effort involving INTERPOL and 28 countries and territories. It was designed to tackle illegal online football gambling during the UEFA 2024 European Football Championship, which was predicted to generate a surge in betting turnover, and lucrative profits for criminal organisations.

The illegal gambling market is worth a staggering USD 1.7 trillion globally, according to research by the Asian Racing Federation, and is closely tied to other criminal enterprises. Beyond shutting down tens of thousands of illegal websites, SOGA X investigations also led to the rescue of trafficked workers and the exposure of money laundering syndicates.

Hundreds of human trafficking victims rescued in the Philippines

In one significant case in the Philippines, local authorities, supported by INTERPOL, dismantled a scam centre operating alongside a licensed gambling site. The operation resulted in the rescue of more than 650 human trafficking victims, including almost 400 Filipinos and more than 250 foreign nationals from six different countries. Many of the victims had been lured to the location with false promises of employment and were kept there through threats, intimidation, and even passport confiscation. They were then forced into working for the legal gambling site, while also running illegal cyber scams, including romance scams and cryptocurrency-related fraud.

An INTERPOL Operational Support Team provided vital assistance to Filipino authorities on the ground, providing expertise in extracting and analysing forensic evidence from seized devices, tracing illicit financial flows and identifying potential victims and suspects in other jurisdiction.

The SOGA X operation also cracked down on large-scale illegal betting sites and complex financial crime schemes.

One notable example from Vietnam, where online gambling is prohibited for citizens, saw authorities dismantle a sophisticated gambling ring that was generating a staggering USD 800,000 in daily transactions.

The syndicate, powered by servers located in multiple countries, used an elaborate network of bank accounts and e-wallets to receive illegal gambling bets and distribute payouts.

In Thailand, police raided two locations hosting major illegal betting websites, arresting the ringleaders and their network for gambling and money laundering offenses and seizing assets worth over USD 9 million.

In Greece, authorities took down a major illegal betting ring that exploited fake and mule user accounts to place bets on sports events. The organised crime group, which employed Virtual Private Networks (VPNs) to bypass internet blocks in Greece, operated at least seven illegal gambling sites and had access to accounts on 60 other illegal websites.

The group managed 3000 fake and ‘mule’ user accounts on legal gambling websites in Greece, Cyprus and Spain. The accounts had been created using both stolen identity cards and forged documents and often utilised e-wallets to facilitate their illegal activities. During the investigation seized laptops were found to contain 9000 pictures of fake ID cards.

The goal of this type of scheme is to break down large sums of money into smaller, less detectable amounts. By dispersing their profits across multiple accounts, criminals aim to avoid detection by law enforcement, financial institutions and legitimate gambling sites. It’s a method also used to facilitate money laundering.

SOGA X was a coordinated effort led by INTERPOL, with crucial support from the Asia-Pacific Expert Group on Organised Crime (APEG), the INTERPOL Match Fixing Task Force (IMFTF) and operation partner UEFA. INTERPOL facilitated intelligence sharing among participating countries, providing case mentoring and training for local authorities.

Stephen Kavanagh, INTERPOL Executive Director of Police Services, said: “Organized crime networks reap huge profits from illegal gambling, which is often intertwined with corruption, human trafficking, and money laundering. The successes of Operation SOGA X would not have been achieved without global information sharing and significant efforts by law enforcement authorities on the ground.”

Illegal gambling can also be closely tied to match-fixing as criminals attempt to manipulate the outcome of sports events to guarantee profits. When illegal gambling is rampant, it becomes easier for corrupt individuals to influence games, so the SOGA X operation also aimed to intercept and interrupt any signal of manipulation. Related investigations are still ongoing.

The Swedish National Audit Office has examined the Swedish Gambling Authority’s supervision of the Swedish gambling market. The overall conclusion is that supervision is not sufficiently effective to meet the expectations expressed by the Riksdag and Government in connection with the reregulation of the gambling. market. This particularly concerns the fact that the Swedish Gambling Authority conducts few inspections, but also that its choice of which actors are selected for supervision is not based on well-founded risk analyses. The Swedish Gambling Authority also does not sufficiently follow up whether the supervised entities rectify the identified deficiencies.

On 1 January 2019, a license system was introduced for the Swedish gambling market. Under this reform, in principle all gambling for money must be operated under public control to protect players and to ensure revenues to the Government and for the purpose of public benefit. Essential preconditions for achieving the aim of the reform included substantial channelling of gambling to licensed operators and their compliance with the regulations. The Swedish Gambling Authority’s supervision of both the unlicensed and the licensed markets thus plays a central role in the reregulated system.

The Swedish National Audit Office considers that supervision in the form of inspection, in which individual license holders are examined and non-compliance has consequences is particularly important when there is a high risk of regulatory violation. From this perspective, the number of inspections of commercial online gambling and betting has not been sufficient in recent years. In the submarkets. where central government and public good have exclusive rights, supervision has been very limited in recent years. The Swedish National Audit Office considers that the perception and credibility of the system is directly linked to the regular supervision of all types of licenses and forms of gambling.

The Swedish Gambling Authority’s supervision of unlicensed gambling is important, as illegal gambling can undermine the legitimacy of the licensing system. At the same time, it can be recognised that, in practice, the Swedish Gambling Authority’s possibilities to take measures against illegal gambling are limited. The lack of clarity in the Gambling Act also hampers these efforts. This lack of clarity has been pointed out in the past without the Government taking initiatives to address the problem.

The Swedish Gambling Authority has given supervision lower priority in relation to competing tasks. These include license and permit applications, as well as government assignments and other tasks that have been added gradually without the addition of corresponding resources to the Authority. All in all, this has contributed to the limited scope of supervision. The Government has been aware of these circumstances but has not take of of informed the Riksdag.

The reregulation of the gambling market has involved a radical reform, implemented at a high pace. For the Swedish Gambling Authority, the initial years have entailed an intensive period of development. At times, adequate solutions have been arrived at quickly, while in other cases, the process has been more protracted. On the whole, the Swedish Gambling Authority has established appropriate processes and support for supervision and for managing conflicts of interest. However, the Swedish Gambling Authority has so far not followed up on the results of its supervisory decisions. The Authority therefore does not know whether the identified deficiencies have been rectified and thus lacks knowledge of whether the use of inspections has been cost- effective. The Swedish Gambling Authority also needs to develop its planning process for supervision; for example, its risk analysis needs to be more systematic.

The Gambling Act, which forms the basis of today’s licensing system, was designed as a framework law to allow regulation to be adapted to the rapid development in the gambling market. The Government has initiated several amendments to the Act and decided on several amendments to the ordinances to adapt the regulations and give the Swedish Gambling Authority increased powers and new tools. This is a positive development, according to the Swedish National Audit Office. The Government must continue to actively monitor developments in the gambling market and, if necessary. take measures to further develop the regulatory framework and ensure that the Swedish Gambling Authority has sufficient powers and effective tools for its supervision.

Recommendations

The Swedish National Audit Office makes the following recommendations.

To the Government

• Ensure that the Swedish Gambling Authority has the conditions to carry out effective supervision to a sufficient extent.
• Ensure that reliable and accurate information on the scope and results of the supervision are produced and inform the Riksdag accordingly.
• Investigate the question of the scope of the Gambling Act in order to clarify in what cases online gambling is covered by the Gambling Act. In this context, consider the possibility of expanding the scope.

To the Swedish Gambling Authority

• Develop the arrangements for planning, managing and following up supervisory activities. This should include systematic risk analysis. There should also be longer-term planning, in addition to the annual supervisory planning.
• Work actively to increase the scope and effectiveness of the Authority’s inspections of both the licensed and unlicensed gambling markets. This should include an examination of the conditions for reallocating resources within theu Authority.
• Continue to develop the Authority’s methods and support for supervisory activities. This should include procedures to verify that the supervised entities rectify the identified deficiencies.