Dutch Study Warns of Player Risks in Black Market Gambling

A new study has raised concerns about the risks facing Dutch players who gamble with unlicensed offshore operators, including the possibility of losing winnings without explanation and the misuse of personal data.

The research, published by Quality Mark Responsible Affiliates (KVA), examined six illegal gambling operators accessible to players in the Netherlands. Among them were Booms Bet, Vegas Hero and Tomb Riches—brands that are searchable through the term “casino without Cruks”, a reference to the Netherlands’ national self-exclusion register.

KVA, an advisory board set up by legal firm XY Legal Solutions, tested the operators by creating anonymous player accounts. The investigation found players were able to register and gamble without identity verification, exposing them to further risks, including underage participation. Three of the six sites accepted deposits from youth bank accounts, meaning minors could bet illegally.

 

Data Privacy Risks

The study highlighted significant issues around personal data. Content analysis of the operators’ privacy policies revealed that all six allowed for the transfer of player information to third parties based outside the EU. KVA concluded that this practice left players vulnerable to “extensive and unlimited data sharing with commercial partners,” with little to no protection under EU privacy standards.

KVA also reviewed the operators’ terms and conditions, finding inconsistencies and what it described as “one-sided and unreasonable” clauses. These included provisions allowing operators to close accounts, delay or refuse payouts, and in some cases, withdraw player winnings without explanation. The lack of regulatory oversight also raised questions about fair play. Without approved gaming systems, illegal operators could manipulate outcomes, according to the study.

The findings come as the Netherlands continues to strengthen consumer protection measures in its legal gambling market. The Dutch gambling authority (KSA) has implemented player deposit limits, restricted advertising and banned sponsorships. While these steps aim to prevent problem gambling, KVA’s research suggests they may also be driving players toward unlicensed operators. Traffic to illegal gambling sites rose sharply following the introduction of deposit limits in October 2024. Visits jumped from 172,576 in that month to more than 412,000 by February, the report found. The number of domains linked to illegal operators also grew, reaching 72 in March compared with 19 last October.

 

One of the most common risks faced by players betting with illegal operators is extensive and unlimited data sharing with commercial partners.

 

A Growing Black Market

The study underscores the challenge facing regulators: measures designed to protect players may be unintentionally expanding the black market. With no KSA supervision, players on illegal platforms lack the safeguards available in the regulated sector, including deposit limits, exclusion tools and verified fair play systems. The report concludes that the combination of weak consumer protections, exploitative terms and excessive data sharing makes illegal operators a significant threat to Dutch players.