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

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.