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Messaging and targeted advertising: The restriction also extends to instant messaging, SMS, email, notifications, advertising automatically targeted by algorithms, telemarketing – which shows ads again to people who have already been exposed to certain content – and profiling based on user behaviour.

Other means of dissemination: The prohibition includes advertising in electronic games and esports, sports uniforms and equipment, public transport and affiliate content, tipsters, comparison sites and other paid intermediaries.

Promotions and benefits: Bonuses, promotional credits, free bets, cashback, free spins, rewards and loyalty programmes used to encourage membership, retention or return to betting are prohibited.

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In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.

Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation. 

This points to a wider shift towards addressing organic search signals and domain-level practices such as doorway pages, an issue also raised in the UK, where research has linked black market migration to search-driven promotion and SEO exploitation.

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