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In this context, the regulations developed to protect players begin to function as a means of legitimisation, with illegal operators even using the term “authorised” in their communication and the “.bet” extension in their domain, which is intended only for licensed operators.
According to the governance policies of Meta, the owner of Instagram, gambling platforms can use programmatic advertising services and branded content, provided they receive authorisation from the platform. They cannot target content to individuals under 18 or territories where gambling is not regulated.
To obtain Meta’s approval, the company needs to fill out a form and attach documents proving its operating licence. This same form includes a contract, in the form of an “I accept the terms and conditions” button. In it, the advertiser releases Meta from liability for any violations of the content, including legal or administrative proceedings.
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Speaking at the 2026 South East Region Staff Excellence Awards in Gaborone, Kemorwale said unlicensed platforms were diverting an estimated P850m ($63.2 million) from Botswana’s economy each year and exposing children and teenagers to unregulated gambling.
He described the rapid growth of the illegal online market as one of the sector’s most serious challenges.
The bill would amend the Gambling Authority Act to align it more closely with the Financial Intelligence Act and Financial Action Task Force standards. Its memorandum says the changes are intended to strengthen anti-money laundering requirements and reduce financial crime risks.
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The report utilised various methods to estimate the size and scale of Europe’s black market, including web traffic, digital marketing, macros data and regulations in place across the 28 markets surveyed.
Helios, a specialist consultant in gambling web traffic, analysed the number of black market websites actively marketing across the 28 markets included in the report, between March and May.
This data was cross referenced with SimilarWeb traffic analysis to confirm the scale of activity. In some markets, the number of illegal sites being actively marketed was much higher than those that have local licences to operate.