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The Dark Side of KYC and Online Casino Regulation in the UK: A Systematic Review of Literature

Authors: Norman, David;

The Dark Side of KYC and Online Casino Regulation in the UK: A Systematic Review of Literature

Abstract

This systematic literature review examines the unintended consequences of enhanced Know Your Customer (KYC) requirements implemented by the UK Gambling Commission since May 2019. Drawing upon academic research, industry data, and government statistics, this study analyses how mandatory identity verification has created systematic barriers that disproportionately exclude vulnerable populations from regulated gambling services. The review employs a social justice framework to evaluate the discriminatory effects on unemployed individuals, disabled people, women, cash-paid workers, and other marginalised groups who cannot meet stringent documentation requirements.Key findings reveal a 522% increase in black market gambling activity between 2021–2024, with 67% of self-excluded gamblers circumventing protections through unlicensed platforms. Analysis of search behaviour and affiliate marketing demonstrates a clear bifurcation between sites promoting regulated operators and those explicitly targeting KYC-excluded individuals with “no verification” cryptocurrency casinos. The displacement effect contradicts fundamental addiction psychology, as neurobiological research indicates compulsive gambling behaviours redirect rather than cease when faced with administrative barriers.The review identifies significant policy failures, including the absence of criminal penalties for consumers using unlicensed sites and the loss of £36.9 million annually in Remote Gaming Duty to black market operators. International evidence supports graduated, risk-based KYC approaches that balance harm reduction with accessibility, whilst current UK policy intensifies restriction-based measures despite evidence of counterproductive effects.The study concludes that KYC enforcement has transformed consumer protection measures into instruments of financial exclusion, creating a two-tier system where privileged populations access safer regulated services whilst working-class problem gamblers face dangerous unregulated alternatives with no consumer protections. Reform recommendations include implementing tiered verification systems, universal deposit limits without full KYC, and time-based controls that prioritise actual harm reduction over regulatory compliance.The study also delves into a paradigm shift in online search habits which demostrate a shift from the traditional affiliate gambling market which promoted licensed online casinos, to a new breed of search affiliate who are cashing in on the trend for user searches favouring "no Gamstop" and "no KYC".

Related Organizations
Keywords

Social Justice, Vulnerable Populations/legislation & jurisprudence, financial exclusion, Harm Reduction/ethics, Vulnerable Populations/legislation & jurisprudence, gambling regulation

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selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
0
Average
Average
Average
Green
hybrid