Illegal gambling sites appearing in .nl every day
Gambling Authority and SIDN working to intensify collaborative countermeasures
A recent analysis made by SIDN with help from CasinoNieuws.nl shows that abuse of the .nl domain for illegal and misleading gambling activities is on the rise. The findings confirm a report by BNR earlier this month about the proliferation of forwarders from innocent-looking websites to illegal gambling sites. Over a 4-month period, SIDN looked at more than 100,000 domain name registrations, and found that roughly 2,900 had direct ties with online gambling. Apparently innocuous registrations conceal complete gambling sites, copies of licensed gambling sites and pages that redirect to foreign casinos without Dutch licences. And that means significant risks for online players, who are often unaware of what they’re getting into.
From SIDN’s investigation, it’s clear that illegal gambling content in the .nl domain is highly dynamic, with new sites coming online and others disappearing every day. Although such activities are a growing problem, most of the reports about illegal sites reaching SIDN don’t come from licensed content providers, but from people operating outside the law. Effective intervention against this shadowy online market will require closer collaboration by SIDN, the Netherlands Gambling Authority and regulated content providers.
Study design
As operator of the .nl domain, SIDN is able to monitor all domain name registrations in real time. So, over a period of 4 months, it analysed more than 100,000 existing and new registrations: a significant subset of the 6.2 million domain names SIDN oversees. The registrations were checked specifically for brand names, gambling-related terms, suspicious registration patterns and possible links with online gambling platforms.
That led to the identification of roughly 2,900 domain names with clear links to the gambling industry. Of those, nearly 600 belonged to legitimate content providers, or to the government or another industry body. The other domain names and websites were investigated and sorted into the following groups:
1. Illegal gambling sites
The investigation found 112 .nl domain names linked to websites whose operators weren’t licensed by the Gambling Authority, where visitors could nevertheless bet money. Interestingly, a number of Asian gambling platforms appear to be active in the .nl domain, even though they’re not targeting the Dutch market.
Many of the sites in this group pretend to have licences, and allow people to play without checking CRUKS (the Dutch national register of problem gamblers, which legal sites are required to check before letting a person play). People playing on such illegal sites are at increased risk of losing their stakes, because the site operators avoid formal supervision and don’t have a statutory duty of care.
Image 1: Screenshot of the website of an online casino targeting Asian players.
2. Potentially illegal sites
A further 312 domain names were found that, although they weren’t yet linked to active gambling websites, were clearly associated with online betting. The names typically included words such as ‘casino’, ‘gambling’ and ‘bet’. On some days, tens of such names were registered, probably for activation later. The associated registration patterns suggested that their registrants weren’t legal content providers. Nevertheless, it’s hard for the Gambling Authority to intervene while the names are dormant, since no abuse is actually happening. Active monitoring is possible, however, so that immediate action can be taken if the sites do become active.
3. Sites that abuse brand names
A strikingly high number of sites, 121 of them, were abusing the brand names or logos of licensed gambling content providers to make unlicensed content look legitimate. In some cases, the abuse consisted simply of domain names incorporating someone else’s brand name or company name, such as Staatsloterij or Holland Casino. Other cases involved fully operational imitation sites, even with working registration and login functionality.
Image 2: The actual Jacks.nl website.
Image 3: An imitation of the Jacks.nl website.
Unsuspecting players therefore thought they were gambling with a reputable company, when they were actually dealing with an unlicensed operator in another country. As a result, not only did the players risk losing their stakes, but the licensed content providers were losing traffic and turnover.
4. Link sites
Of the domain names investigated, 70 were found to be ‘link sites’. A link site looks like an online casino, but simply redirects the user to a foreign gambling site. As soon as the user tries to start a game, create an account or view more information, they find themselves on the foreign site.
In some cases, the link sites belong to affiliate marketeers who are paid for referrals. Often, however, they’ve been created by marketing agencies working for illegal content providers to generate traffic and boost the profile and search engine status of the destination sites.
5. Reused websites
One noteworthy, growing trend is the reuse of old domain names and websites. What typically happens is that a domain name is used for some years by a legitimate registrant, then cancelled when it’s no longer needed. The website originally linked to the name probably had nothing to do with gambling; it might have been a shoe shop, an information site or an event website, for example. Immediately after the domain name is cancelled and the site taken down, the name is re-registered by someone else. The new owner then creates an imitation of the old site, where all the links lead to foreign gambling sites.
SIDN’s analysis detected more than 1,480 reused websites. In all cases, the links on the sites pointed to unlicensed online casinos or sites where AI-generated articles about online gambling are published every day. Often, SIDN’s researchers came across articles about ways to gamble without being CRUKS-checked, complete with links to the relevant content providers.
Image 4: An example of a reused website for an online casino.
A similar phenomenon was recently investigated by BNR, who also revealed how existing, apparently unrelated websites are used to promote illegal online casinos. SIDN’s research shows that such activities are part of a wider pattern. So the detection of potentially illegal gambling implies looking not only at website reuse, but also at new domain name registrations, registrations of names with no active content, and telltale registration patterns.
“There’s a good reason why these people reuse existing domain names,” says SIDN’s Secure Domains Product Manager Martijn Sanders. “Used domain names have often built up good search engine reputations over a period of years, making them very findable. Illegal gambling content providers try to take advantage of that, so that their content is immediately more prominent in search results than it would have been with a new domain name. To them, a used domain name with a strong reputation is more valuable than a new name.” SIDN is also able to see that pattern in the registration of .nl domain names: it’s the domain names with strong reputations that get re-registered, sometimes with several would-be registrants going after the same used name.
Most illegal site reports come from the unlicensed betting world
Over a 4-month period, SIDN carefully analysed .nl domain name registrations. A striking pattern emerged: every day, new gambling-related websites were appearing, while others were being taking down by SIDN. SIDN is regularly asked to disable domain names because they abuse other people’s brand names or are used for illegal gambling content.
“What stands out,” says Martijn, “is that licensed Dutch gambling content providers practically never report the problem sites. Only a handful of them ever contact SIDN. The majority of the takedown requests we get are from people representing non-Dutch online gambling platforms that aren’t licensed here, or from rival providers of illegal content in the .nl domain, who are trying to rig the market in their own favour.”
Boundary between legal and illegal gambling content
SIDN sees a wide range of gambling-related .nl registrations. However, it’s by no means always clear which websites are legal, and which aren’t. A site with an online casino that isn’t licensed by the Netherlands Gambling Authority is obviously illegal. Things are less clear-cut, though, if a domain name simply forwards to a gambling site operating in another jurisdiction, or if a domain name has links to online gambling, but isn’t currently being used.
Image 5: Screenshot of an online casino website.
Often, it’s difficult for SIDN to decide whether a website is legal or not. Close collaboration with the Gambling Authority is therefore vital in the fight against illegal gambling content, because the Authority needs to decide whether content is permissible. Even with collaboration, there are challenges. If, for example, a content provider is making unauthorised use of a licensed Dutch provider’s brand name, the abuse is outside the Gambling Authority’s jurisdiction. In order to intervene, SIDN needs a takedown request from the brand owner.
Avoiding detection
When SIDN started its investigation, it quickly became clear that various methods are being used to prevent websites being detected as illegal gambling sites. One is to make illegal content available only outside office hours, or only to visitors using certain types of device. So a laptop user sees something different from what someone on a smartphone or tablet sees. Another tactic used by some site operators is to check visitors’ IP addresses and block any known to belong to the authorities.
Although it’s common for sites to hide links to gambling sites in advertisements or banners, some take a more brazen approach. For example, a website that initially looks like an innocent provider of games “for demo purposes only” may interrupt the fun after a few plays and ask “Want to play for real money?” If the user responds by clicking the pop-up, they’re taken straight to an illegal gambling site.
Netherlands is attractive to illegal providers
As Martijn explains, “Under SIDN, .nl is one of the most secure country-code domains in the world. We are very active in abuse prevention, and we’ve set up numerous processes designed to keep our internet zone ‘clean’. As a result, people are more likely to trust .nl websites. And that means that .nl domain names are attractive to illegal content providers.”
Despite active policing of the sector by the Netherlands Gambling Authority, SIDN sees new illegal gambling sites appearing all the time. “The Netherlands is an attractive market for illegal gambling providers,” says Frank Op de Woerd, CEO of CasinoNieuws.nl. “It’s a prosperous country with considerable purchasing power, consumers who are used to online services and electronic payments, and a sophisticated digital infrastructure. That makes Dutch people good prospective customers for international betting firms. At the same time, licensed Dutch providers are constrained by strict rules on things such as advertising, bonuses, player safety and player recruitment. Illegal providers couldn’t care less about the rules, and therefore operate much more ruthlessly. That’s reflected in what they’re prepared to pay marketers and affiliates, which can be 8 times as much as what the licensed providers offer.”
Netherlands is not unique
In the course of its investigation, SIDN spoke to colleagues in Belgium and the UK. They recognised the problems in the Netherlands, because they have witnessed a similar rise in gambling-related domain name registrations in their own zones. The three registries exchanged knowledge and research data on matters such as prevalence, detection and the challenges associated with intervention.
What can be done differs from country to country, depending on the powers of the regulatory authorities and the national registry’s rules on domain name registrations. Stricter rules make it easier to disable problem domain names, but also make it harder to register domain names for legitimate purposes.
Why doesn’t SIDN prevent the problem registrations?
SIDN doesn’t prejudge domain name registrations. It’s not possible to know at the time of registration that a domain name will ultimately be used for illegal content or brand name abuse. Take the name ‘Ajax’. If someone registers a domain name based on ‘Ajax’, SIDN cannot know whether it refers to the football club, the cleaning product, the fire extinguisher or the Greek mythological hero.
However, SIDN can flag up the potential risks to the brand owners or the authorities, so that they can decide whether their brand is being abused or illegal content is being provided. SIDN can respond to an intervention request by deactivating a domain name only if the associated website is clearly breaking the law. Deactivation of a domain name prevents it being used to access the associated content, but it’s something that SIDN does only under exceptional circumstances and in accordance with strict internal procedures.
What next?
Since the start of the investigation, nearly 1,800 domain names have been taken offline by SIDN. The great majority were drawn to SIDN’s attention by anonymous complainants, with the Netherlands Gambling Authority also reporting 360 or so domain names. However, numerous other cases are still awaiting assessment by a brand owner or the Gambling Authority. SIDN has shared its findings and the supporting dataset with the Gambling Authority in anonymised form.
“Our investigation has provided valuable intelligence, but the data is ultimately just a snapshot,” says Martijn. “New malicious gambling sites are being created all the time, so the landscape is highly dynamic. Without systematic collaboration by SIDN, the Gambling Authority and the licensed gambling industry, a considerable portion of the illegal content is going to go undetected.”
Continuous monitoring, early warnings and proper follow-up are needed to tackle this problem. SIDN and the Gambling Authority are therefore planning to work more closely together. “What we want to do next is put this approach on a structural footing,” says Martijn. “Then, instead of action against new illegal gambling sites having to wait until they are up and running in public, we can flag them up soon after the domain names are registered, enabling prompt intervention.”
