The Polish government has historically relied on domain blacklists and strict advertising restrictions under the country’s Gambling Act, but these measures proved insufficient against a digital ecosystem capable of regenerating faster than regulators could respond.
Recent enforcement operations represent the first large-scale action directed at the social media layer of the grey market, signaling a broader transformation in how Poland addresses illicit online gambling. By expanding enforcement beyond operators and their websites into promotional and financial channels, Polish authorities are adopting a model similar to several other European jurisdictions that treat grey market gambling as a systemic challenge involving technology, finance, media, and consumer protection.
Enforcement Targets Influencer Promotion Networks
The growing dependence of unlicensed operators on influencer-driven promotion has driven the escalation of enforcement activities in Poland. Offshore brands have combined traditional web advertising purchased through foreign networks with influencer marketing across platforms including Kick, YouTube, TikTok, and Twitch.
Marek Plota, managing partner at RM Legal, explained that this dual structure proved particularly resilient because influencers provided authenticity and immediacy that translated into high engagement from younger audiences. Domain blocking could be bypassed within minutes through mirror sites and rotating URLs, while anti-promotional provisions were difficult to enforce when marketing originated on global platforms with no operational presence in Poland.
The arrests of high-profile streamers represent a structural reorientation in which authorities treat the social media layer as a core component of illegal casino infrastructure that must be addressed with the same seriousness as the operators themselves.
Financial Supervision Authority Disrupts Payment Channels
The financial dimension of the crackdown has intensified through direct supervisory pressure from Poland’s Financial Supervision Authority (KNF). The regulator issued a sector-wide warning to payment service providers demanding immediate verification of whether they facilitate transactions linked to unlicensed casinos and instructing them to discontinue such activity.
The communication marks a shift in expectations placed on the financial sector. Poland’s gambling-related payment flows are now explicitly framed within anti-money laundering and counter-terrorist financing obligations, requiring payment service providers, banks, and fintechs to treat these transactions as high-risk financial activity.
Market reaction has been rapid, with several payment methods including BLIK disappearing from offshore casino sites shortly after the KNF correspondence. The disruption affects both deposits and withdrawals, breaking payment chains that previously allowed Polish users to move funds in and out of illegal platforms with minimal friction.
For offshore operators, this undermines a critical pillar of their business model. For authorities, it demonstrates that financial supervision can reduce the operational viability of unlicensed gambling operations.
Coordinated Regulatory Framework Supports Enforcement
The enforcement actions are supported by structural changes within Poland’s regulatory administration. The creation of a dedicated Gambling Regulation Department within the Ministry of Finance, combined with the launch of the Inter-Ministerial Team for Countering the Grey Market, has established a framework for sustained cooperation between tax services, customs authorities, prosecutors, supervisory bodies, and digital platforms.
This institutional architecture enables coordinated monitoring of promotional patterns, payment anomalies, and advertising behaviors. The approach has evolved into a three-level strategy focused on disrupting visibility through actions directed at influencers and affiliate networks, constraining access through improved domain control and digital monitoring, and severing transaction channels through pressure on payment institutions.
“The integrated nature of this approach reflects an understanding that illegal casinos operate as decentralised networks rather than isolated websites. Effective enforcement therefore requires addressing every layer of that network simultaneously instead of relying solely on static blocking measures.”
Operational Risk Increases for Grey Market Participants
The combined enforcement actions have shifted the risk landscape for illegal casino operations in Poland. Influencers, agencies, and affiliate marketers who previously operated with minimal exposure must now reassess the legal and financial consequences of promoting offshore brands. Payment providers face heightened scrutiny requiring strengthened due diligence mechanisms to evaluate whether their systems indirectly enable gambling transactions.
Offshore operators can no longer rely on familiar avoidance tactics such as domain rotation or alternative settlement routes, as each layer of their operational model now faces regulatory pressure.
Whether these measures will lead to a long-term reduction in grey market activity depends on the persistence of supervision and the ability of enforcement agencies to evolve with new technical workarounds. Poland has moved decisively beyond reactive domain blocking toward an enforcement strategy that views illegal gambling as a networked ecosystem and applies pressure to every component simultaneously.
Industry experts have called for an end to Poland’s iGaming monopoly to address the grey market and tackle the growing black market presence.
Source: iGaming Business
