Illegal Gambling and Licensed Play Overlap in UK Banking Study
People detected using illegal gambling operators often continued using licensed ones. In an open-banking study published on October 28, Britain’s Gambling Commission found that 91% of people with repeated detected illegal transactions also gambled with licensed operators. That overlap complicates the idea that customers simply leave one market for the other.

What the researchers actually counted
The Commission’s published results describe two matching exercises. Exact transaction-description matches with known illegal operators produced 821 transactions. Merchant-name matches with strongly suspected illegal operators produced 2,628. After removing 23 overlapping matches, the researchers had 3,426 transactions involving 179 people.
Those are detected transactions, not the total value of illegal bets, operator revenue or profit. The distinction matters because a transfer into a gambling account does not tell you how often that money was subsequently staked.
The wider dataset contained 4.8 million licensed non-lottery gambling transactions and 157.2 million transactions overall. Dividing the detected illegal count by either larger figure would produce a neat percentage, but it would not establish the illegal market’s share. The matching method could identify only activity it recognised, and the panel was not nationally representative.
The overlap is more useful than a market-size shortcut
The 91% finding applies to the subgroup with repeated detected illegal transactions, rather than every person in the study or every British gambler. It nevertheless gives a concrete reason to examine activity across both types of operator.
A licensed account and an illegal account can coexist. For research and consumer protection, that means evidence of continued licensed play cannot, by itself, rule out illegal activity elsewhere. Equally, the study does not establish why a particular person used an unlicensed operator or whether their spending moved away from a licensed business.
Our earlier examination of Britain’s URL-removal figures makes a related measurement distinction: enforcement actions count something different from customers, businesses or gambling revenue. The banking study adds another unit, with its own limits.
Read the harm scores within this sample
Problem Gambling Severity Index scores were available for 146 of the 179 people with detected illegal transactions. Of those 146, 45% scored eight or above, compared with 6% in the study’s licensed non-lottery group of 12,543 people.
That is a substantial difference within the dataset. It is not a national prevalence estimate, and the Commission cautions against direct comparison with the Gambling Survey for Great Britain. Nor does the association prove that illegal gambling caused the higher scores.
The report therefore supports a narrower, useful conclusion: detected illegal activity and licensed gambling frequently overlap, and the detected group had higher harm scores within this panel. Establishing national market size, spending migration or cause and effect requires evidence beyond these matches.
