The Rules, standards and policies governing iGaming advertising in Europe are more fragmented than ever before. The backdrop sees regulators stepping up oversight and handing out multi-million-euro fines to platforms and publishers.

From the Med to the Baltics, all forms of media are under tighter scrutiny, reinforcing the message that campaigns must stay within strict regulatory remits or face severe penalties. Presenting SBC with a regulatory intelligence factsheet,  Partner and Head of Consulting at 4H Agency, maps the shifting advertising landscape from Western to Eastern Europe. His analysis warns that affiliates, operators and intermediaries alike are now in regulators’ crosshairs.

The briefing precedes a 4H Agency webinar on 30 September, where Kurochkin and industry experts from Voluum and Lift DSP will debate the compliance risks and growth opportunities facing iGaming marketers in 2025.

iGaming Advertising in 2025: Navigating Legal Risks

1. Common licensing pitfalls for new advertisers

New advertisers entering regulated sectors often underestimate how many licensing traps lie beyond the obvious do’s and don’ts.

Some of the sharpest lessons come from gambling regulation in Europe, where enforcement actions illustrate just how costly a misstep can be. Italy, for example, has fined Google, Twitch and Twitter for hosting or circulating content that was considered gambling promotion, with penalties running into millions of dollars. Spain has repeatedly attempted to re-introduce near-total bans on gambling marketing, while in the Baltics, Lithuania has already moved to prohibit the use of betting brands in the names of sports clubs and leagues. Attempts to bypass the rule (such as rebranding the football A-league as “TOPSport supports A-league”) were still deemed violations. Latvia and Estonia are also preparing tighter frameworks. These examples show that regulators are not only rewriting rules but also interpreting them in the strictest possible way, leaving little room for creative workarounds.

Beyond regulatory bans, advertisers frequently fall into contractual traps that can undermine both commercial value and compliance. The most common include:

• Ambiguous contract language – vague definitions of “reasonable use,” territorial scope, or media rights create conflict when interpretations differ.
• Exclusivity without safeguards – granting exclusivity with no performance conditions can lock advertisers into unproductive deals.
• Uncontrolled sublicensing or assignment – allowing rights to pass to third parties without oversight undermines brand control and compliance.
• Hidden financial risks – unclear royalty calculations, undefined deductions, or lack of audit rights can erode expected revenue.
• Weak quality control provisions – without strict standards and approval processes, sub-par materials may damage brand reputation or breach regulations.
• Regulatory change exposure – contracts that ignore shifting laws (e.g. sudden advertising bans) leave parties facing compliance crises.
• Missing termination and exit clauses – without clear exit triggers, advertisers risk being trapped in unfavorable contracts.
• Unsecured IP rights across markets – operating in jurisdictions where trademarks or copyrights are not properly registered can lead to disputes and counterfeiting.

All of these traps are amplified by a broader trend: regulators are increasingly willing to impose heavy penalties not just on direct advertisers, but also on platforms, sponsors, and intermediaries. For new advertisers, compliance is not just about the wording of a contract but also about monitoring how content is distributed and consumed in practice.

1. Affiliate marketing in white, grey, and black markets

The affiliate model in online gambling is directly shaped by the legal environment. Broadly, there are three categories: white (regulated), grey (unregulated), and black (prohibited) markets. Each comes with its own compliance expectations, monetization limits, and risks – affiliates must adapt accordingly.

• White Markets – offer lower rev share but long-term stability: trusted payments, enforceable contracts, and sustainable user flows. Affiliates can promote only licensed operators under strict rules:
  • Creative limitations: no “easy money” claims, no targeting minors, celebrities, or patriotic themes.
  • Media restrictions: campaigns may be limited to late-night TV, subscription platforms, or operator-owned channels.
  • Shared liability: regulators now hold not only operators but also affiliates and media platforms accountable.

E.g., in Denmark, a Twitch streamer was fined ~US$1,500 for promoting unlicensed casinos. In the Netherlands, CasinoScout.nl listed offshore casinos and received escalating fines of ~US$88,000 per week before the site was shut down.

• Grey Markets – offer higher CPMs and rev share but with unstable traffic and regulatory unpredictability. These jurisdictions do not explicitly ban gambling but lack formal frameworks:
  • Typical tactics: SEO “best casino” lists, native advertorials, and geo-targeted paid campaigns.
  • Risks: sudden enforcement, ad platform restrictions, and scrutiny of affiliate media chains.

E.g., in early 2025, India’s ASCI flagged 413 promotional materials related to offshore operators and 12 potentially non-compliant ads. Between April 2023 and March 2024, ASCI reported 1,336 similar cases, leading to access blocks and ad removals.

• Black Markets – may promise the highest payouts from crypto-casinos and offshore brands, but the risks far outweigh the benefits:
  • Common practices: cloaking, redirects, drop domains, and traffic through messaging apps or private groups.
  • Strict enforcement: affiliates and influencers are increasingly being targeted alongside operators.

Therefore, in white markets, affiliates must stick to licensed offers, keep compliance records, and tightly manage ad approvals. In grey markets, adaptability is key – diversify traffic, use clear disclaimers, and expect policy shifts. In black markets, the risks are personal, including criminal prosecution. With global enforcement tightening and platforms raising standards, affiliates are no longer peripheral: they are now central and accountable actors. Compliance is not just protection, it’s a strategic advantage.

1. Best GEOs for affiliate marketing

Some of the most dynamic and profitable affiliate opportunities today are concentrated in Eastern Europe and the CIS region. These markets combine engaged audiences, varied regulatory landscapes, and strong monetisation potential, making them particularly attractive for experienced affiliate teams. In Eastern Europe and the CIS, three affiliate markets stand out: Kazakhstan, Ukraine, and Georgia – each with its own mix of scale, risk, and revenue potential.

• Kazakhstan – high volume, intense competition. Kazakhstan offers solid ROI potential (25-30% and up), driven by steady demand and a familiar user base. However, the market is overcrowded. High ad costs, low average deposits, and aggressive “clickbait” tactics complicate returns. Affiliates must adapt to a split audience: a broad Russian-speaking segment and a smaller, culturally distinct Kazakh-speaking group.
• Ukraine – the region’s top performer. Ukraine remains the most advanced and scalable GEO, home to the region’s largest affiliate teams. ROIs often exceed 70-100%, but competition is fierce and requires strong brand partnerships and campaign scale. Small teams struggle unless they resort to black-hat methods. Localization and innovation are key to success.
• Georgia – small scale, regulatory stability. Georgia is regulated and stable, with ROIs of 30-50%. However, a small population and strict ad rules limit growth. Acquisition costs are high, and platforms like Facebook and Google often reject ads. Affiliates succeed here by tailoring creatives and complying with local norms.

Other markets like Armenia and Poland lag behind due to limited size or tighter restrictions. For affiliates, Ukraine is the growth engine, Kazakhstan offers reach with challenges, and Georgia provides controlled, moderate returns.

1. Compliance and Sustainable Affiliate Growth

Affiliates and operators must approach compliance not as a defensive measure but as a growth strategy. The most effective practices can be distilled into four pillars:

• Work only with licensed partners – in regulated GEOs, avoid grey shortcuts. Every campaign should clearly display license details and responsible gambling warnings.
• Localise with precision – adapt language, cultural cues, and promotional hooks to each GEO. In markets like Kazakhstan, dual audiences require differentiated messaging; in Georgia, content must meet strict creative rules.
• Control the full chain – audit creatives, monitor distribution channels, and document approvals. Regulators are increasingly targeting intermediaries, so affiliates need compliance logs as much as operators do.
• Diversify and future-proof – in grey environments, balance SEO, paid traffic, and sponsorships, while preparing for sudden bans or platform crackdowns. This minimizes exposure to single-channel risks.

The pattern is clear: regulators demand stricter standards, and platforms enforce them rigorously. Affiliates who treat compliance as a competitive advantage, rather than a cost, are the ones who will stay profitable and scalable across shifting GEOs.

If you’re interested in the above content and insights join the joint webinar with experts from 4H Agency, Voluum and Lift DSP, where these topics will be discussed in depth and you’ll have the chance to ask your questions.

The webinar will take place on September 30 at 15:00 CEST. Register here: https://voluum.com/webinars/igaming-ads-legal-restrictions/