In this SPECIAL INVESTIGATIVE INFOPLAY, we expose an illegal practice of promoting unregulated gaming operators in Spain by a highly reputable media outlet. A specific and very significant example of how the shadow of illegal gambling is a real threat, affirming the warning from the sector: strict advertising regulation is counterproductive and encourages unauthorized illegal gambling.
After nearly twelve years of regulated market in Spain, the line between informative content and covert advertising has become increasingly blurred. A clear example of this issue is the case we present in this SPECIAL INFOPLAY, which we hope will demonstrate that, despite the strict regulation of gambling and its commercial communications in Spain, the promotion of unregulated gaming operators is a real and very current threat in 2024.

Through a comprehensive analysis based on evidence, and after consulting with various experts on legality and sector marketing, we expose a blatant transgression of the current legislation, which also raises serious ethical questions in terms of responsible gaming.

1. What have we discovered?

Essentially, that a renowned sports information website whose header belongs to a prestigious Spanish press group is promoting unregulated gaming operators in Spain through written content published, accessible, and indexed on Google, in what would be an action that directly contravenes the current gambling regulations in Spain, especially the Royal Decree 958/2020, of November 3, on commercial communications of gambling activities.

This investigative article unravels the layers of this presumably illicit operation, supported by compelling evidence such as screenshots, links to the published content, detailed analysis of the infringed articles, and opinions of relevant personalities whom we have consulted.

2 - Description and Presentation of the Fact

Regardless of other aspects that we will be publishing shortly (related to the network of affiliate agreements with various unregulated gaming operators, strategies for search engine positioning, the use of artificial intelligence to generate content that attracts users to these illegal operators, or the explicit promotion of bonuses, payment methods, and non-permitted products), the initial certainty we want to expose is apparent just by reading the headline of the article or its URL.

Screenshot taken on February 25, 2024, of the first part of the analyzed article

As we can observe - quoting textually - the article details and describes in its headline what are the "best unlicensed casinos in Spain", also offering a guide on how to "remove self-exclusion from gambling" (specifying later that it refers to the General Registry of Gambling Access Bans (RGIAJ)).

Web address (URL) of the analyzed article

In the URL itself from which the article is accessed, the leitmotif of the content can also be confirmed, explicitly highlighting "best unlicensed casinos" and "remove self-exclusion from gambling".

But if we continue reading the more than 11,000 words that shape the article, we will be surprised to find how the practice of promoting up to a dozen unregulated gaming operators (with explicit links to their main pages or their direct registration pages), is joined by what apparently seem to be many other transgressions of specific norms that appear in the aforementioned Royal Decree on Commercial Communications of 2020 and that since the Law 13/2011, of May 27, on gambling regulation seemed to be evident.

Here we only cite some:
  • Content not tolerated in the regulation
whether they are affiliates or considered media (with which operators reach agreements directly or through departments or Media Buying agencies), since 2021 terms that have a "negative" consideration or go directly against regulatory compliance cannot be used.

In this article, we observe more than a hundred phrases that include mentions of money, explicit promotions, bonus amounts, etc. A veritable string of promotional content that no legal operator is currently using.
  • There is a ranking of the "best" illegal operators, based on variables such as the amount of their bonuses or the use of cryptocurrencies.
In addition to the absence of the +18 symbol in the more than 20 promotional images found in the article (which does appear when accessing the page through a pop-up that is indeed required by current legislation), messages about "Play Responsibly" are not observed; instead, the content focuses on the opposite, offering promotional codes for deposits in cryptocurrencies or real money, bonuses of up to €6,000, or even boasting that the recommended casinos are "registered and licensed in Curacao".

  • Appearance of Currencies Other Than the Euro (EUR)
Even among the bonuses and explicit promotions, text and images are offered with amounts and prizes in foreign currency (USD).

  • Affiliate Code in Each Link to an Illegal Operator
Although we would like to dedicate a new article to focus on this aspect, it is clear that all the links available in this article contain a "tracking" code that identifies players who subsequently register with the operators as "referred" by the affiliate (whether it be or some intermediary).

As we have already advanced, there are many more points that we believe challenge the legal regulations established to regulate the advertising and promotion of gambling in Spain. We have located several similar articles published in 2024, promoting crypto casinos and using messages that are not subject to Spanish regulations.

We will publish more information on this in the coming days...

3 - The Central Thesis

With what has been observed in the previous section, it could already be considered that we are facing an alleged violation of the Royal Decree 958/2020, of November 3, on commercial communications of gambling activities.

But regardless of the challenge to the current legality (it will be the Spanish Regulator who will have to evaluate it and act accordingly), it seems clear that this lucrative form of advertising should make us reflect on the ethical implications of promoting operators that do not offer guarantees linked to the general gaming licenses; or the challenging task of pursuing unauthorized illegal gambling.

4 - How Did This Happen?

This failure to protect consumers, which is also an attempt to defend the integrity of most media outlets, occurs primarily due to overly strict regulation of commercial communications, which facilitates the entry of operators and agencies with no interest in Spain, capable of paying high amounts to attract traffic (potential customers).

Indeed, after consulting with an SEO and SEM expert from a regulated operator, it is even possible to estimate the price that could be paid for an article of these characteristics (which exceeds 11,000 words and promotes a dozen operators): "a figure that should exceed €10,000 and that would also be significantly increased by variable income depending on the players registered from those links".

Additionally, another professional from a Spanish operator warns us of the "call effect to foreign unlicensed operators who, given the difficulty that regulated operators have in competing in price, take risks and invest large sums in attracting players who either search on Google for unlicensed operators or for promotions and offers currently not available in Spain".

An example of what can happen in Spain is what we have been seeing for years in Sweden, where nearly 50,000 people search each month for "casino utan svensk licens" (casinos without a Swedish license). Therefore, "having this type of articles in generalist or sports media represents a significant competitive advantage to reach the top positions on Google and attract customers".

In Spain, as of today, there are still only about 1000-1350 monthly searches with keywords about illegal gambling; but we believe that the maxim that the sector has been warning about for some time is about to become a reality: being very strict in the way regulated operators advertise, suffocates the licensed companies and is exploited by illegal operators.

The discovery of the promotion of unregulated gaming operators by a relevant website in Spain, we believe, is not just an isolated case of alleged illegality; it is a symbol of a deeper problem that goes beyond journalism and ethics. This investigation reveals how even in 2024, with extremely restrictive legislation on advertising, there is still a place of maximum exposure to promote illegal gambling.

This article, and subsequent ones that will expand the investigation, not only seeks to inform but also to foster critical discussion on how these situations can be avoided.


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