The ECA position on the future of Europol

The European Casino Association (ECA) calls on the EU institutions to empower Europol with dedicated authority, resources, and partnerships to effectively combat illegal gambling and protect Europe from illegal operators.

The issue

Illegal gambling, both online and offline, poses significant challenges across the European Union (EU). These operations undermine consumer protection, evade regulatory oversight, and deprive the EU economy of legitimate revenues. More critically, they fuel organised crime by enabling money laundering, financing terrorism, and facilitating human trafficking.

The European Commission's 2025 “ProtectEU” strategy rightly aims to strengthen internal security from terrorism, organised crime, cybercrime, and hybrid threats from hostile actors. Strengthening Europol is a central element of ProtectEU. The Commission plans to significantly expand Europol’s mandate, transforming it from primarily a cooperation agency into “a truly operational police agency” with enhanced European-wide capabilities. Europol would gain expanded powers to investigate cross-border, large-scale, complex cases that threaten EU internal security. A detailed proposal for this transformation is expected in 2026. As part of this expansion, the European Casino Association (ECA) urges policymakers to prioritise illegal gambling as a central focus area within Europol’s growing mandate.

Despite its strategic importance, Europol currently faces major limitations in addressing illegal gambling effectively. The sheer scale of the problem is overwhelming: a study conducted by Yield Sec revealed that in 2024 alone, 6,220 illegal online gambling operators actively targeted EU Member States. These unlicensed cross-border entities exploit digital tools and fragmented enforcement systems to thrive with near impunity. Europol, tasked with fostering cross-border law enforcement coordination, is well-positioned to lead the fight against these criminal networks. However, to do so effectively, it requires a clearer mandate, stronger operational authority, and deeper integration with national and EU-level agencies. 

Since 2017, the ECA has collaborated with Europol on Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF), sharing intelligence and expertise. These strategic meetings allow both organisations to analyse current threat landscapes and emerging methods of organised crime networks throughout Europe, with a particular focus on potential impacts on the regulated gaming sector. The collaboration extends beyond regular briefings, with Europol representatives delivering expert insights at ECA Annual Conferences and specialised workshops conducted by the ECA’s dedicated AML and Compliance Working Group. Building on this foundation, the ECA believes that a strategic shift is now needed, one that empowers Europol to proactively combat illegal gambling at scale.

Our recommendations to EU policymakers

The European Casino Association (ECA) welcomes the goals laid down in European Commissioners Brunner and Serafin's mission letters and in the Internal Security Strategy to strengthen Europol’s capacity and mandate by turning it into a 'truly operational police agency'. Concretely, the ECA recommends that any upcoming legislation touching upon the mandate of Europol should include the following elements:

1. Grant Europol targeted investigative authority for illegal gambling

Within a framework of a stronger Europol mandate, the ECA proposes that Europol be granted specific, targeted investigative powers, especially for cases involving suspected illegal gambling activities. This focused enhancement would enable Europol to address a critical area of organised crime while maintaining appropriate jurisdictional boundaries. Such authority would allow Europol to have:

• Specialised cross-border investigation powers: Enabling Europol to launch targeted investigations specifically into suspected illegal gambling networks, whilst working in close coordination with national authorities.
• Streamlined access to gambling-related intelligence:Providing Europol with expedited access to financial records and digital footprints especially in cases of suspected illegal gambling operations.

Why this matters: Illegal gambling syndicates operate seamlessly across multiple European jurisdictions, requiring swift and coordinated intervention. The current system creates critical delays that sophisticated gambling networks exploit. A focused approach to illegal gambling would close these enforcement gaps and deliver more effective protection for both consumers and legitimate operators.

2. Establish a collaborative illegal gambling unit with national authorities and AMLA

Similar to the already established Europol’s European Financial and Economic Crime Centre (EFECC), the ECA advocates for the creation of a permanent, specialised unit within Europol dedicated exclusively to combating illegal gambling, with explicit emphasis on joint operations with both national authorities and the newly established EU Anti-Money Laundering Authority (AMLA). Key features of the platform should include:

• Integrated multi-agency participation:Formalised cooperation frameworks linking Europol with national gambling regulators, law enforcement bodies, FIUs, and AMLA would ensure that intelligence, regulatory insights, and financial crime data are pooled effectively to detect illegal gambling activity at its early stages.
• Secure and real-time intelligence exchange systems: This should include the development of interoperable digital platforms that facilitate the secure, swift exchange of operational information and financial intelligence between participating entities. Such systems would allow for coordinated responses to active threats also online, including illegal cross-border payment channels, unlicensed platforms, and digital advertising networks.
• Strategic integration with AMLA and financial monitoring: European authorities would gain enhanced visibility into complex financial flows that currently enable criminal enterprises to flourish unchecked. The integration would establish a unified front where financial intelligence and law enforcement capabilities merge to create a barrier against illegal operators.

Why this matters: Europol’s successful operations in 2024, particularly those conducted in Portugal “Operation Endgame”, have demonstrated the remarkable effectiveness of collaborative task forces in confiscating illicit assets and disrupting criminal infrastructure. Establishing a permanent collaborative unit would ensure consistent coordination between European and national authorities, creating a united front against illegal gambling operations. 

Moreover, the societal benefits of the integration with AMLA would address the profound social costs of gambling addiction, youth exploitation, and compromised sporting integrity that illegal gambling operations continuously fuel. For individuals, this enhanced enforcement capability would provide greater protection from predatory practices while making sure that legal gambling businesses can properly implement their safety measures to protect players.

3. Enhance Europol’s Role in Enforcing the Digital Services Act (DSA)

Europol's current role in the context of the Digital Services Act (DSA) is primarily related to combating illegal content and criminal offences online, specifically concerning its potential to be designated as a "trusted flagger" and as an authority to be informed of suspicions of criminal offences. In view of the upcoming proposal to strengthen Europol’s mandate, but also the upcoming evaluation and subsequent review of the DSA, the ECA recommends expanding in both legislations Europol’s authority in implementing the DSA, with a specific focus on illegal gambling operations. This expanded mandate would include:

• Collaborative digital monitoring: Empowering Europol to work alongside national authorities to systematically monitor social media platforms and digital advertising networks for illegal gambling content.
• Coordinated enforcement actions: Authorising Europol to support and coordinate Europe-wide responses to unlicensed gambling operators’ websites, applications and payment processing systems.

Why this matters: Research conducted by Yield Sec indicates that over 80% of illegal gambling revenue now flows through online platforms, with these operations frequently marketed through sophisticated social media campaigns. By strengthening Europol’s collaborative capabilities within the DSA framework, the EU could dramatically reduce illegal operators’ digital visibility and accessibility.

4. Expanding Europol’s training and knowledge-sharing mandate

The ECA proposes a substantial enhancement of Europol’s role as the central European hub for training, expertise development, and knowledge dissemination in the field of illegal gambling enforcement. This would build on Europol’s existing intelligence-led mission and enhance its capacity to support national authorities through specialised training, technical expertise, and best practice exchange. The aim is to create a consistent EU-wide baseline of knowledge and operational preparedness in addressing illegal gambling-related crime. This expanded educational mandate would include:

• Comprehensive training academy:Establishing a dedicated Europol training centre specialising in illegal gambling detection, investigation, and prosecution techniques for national authorities.
• Advanced technical training:Providing specialised courses on cutting-edge digital forensics specifically tailored to illegal online gambling platforms and payment systems.
• Annual expertise summits:Hosting regular gatherings of national gambling enforcement specialists to share emerging trends, successful case studies, and evolving criminal methodologies.

Why this matters: National authorities often face significant challenges in developing and maintaining specialised expertise in gambling-related crimes. By positioning Europol as the central knowledge hub, the EU can ensure consistent high-quality training across member states, eliminate knowledge gaps that criminals currently exploit, and foster a community of practice among national enforcement agencies. Recent cases demonstrate that jurisdictions with specialised training achieve substantially higher success rates in prosecuting illegal gambling operations.