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Time to read: 7 min

Profit vs protection: The grey-market tightrope for affiliates

Andreas-Ditsche

Andreas Ditsche examines how affiliates can future-proof themselves as regulation tightens and AI changes the traditional marketing framework.

The affiliate landscape is changing at a pace like never before. More and more countries are tightening regulation around gambling advertising and compliance now has become increasingly fragmented.

Add to that, AI and changing consumer behaviour, means the traditional affiliate model is quickly becoming outdated. So where does that leave affiliates in igaming?

Ahead of the Affiliate Leaders Summit in Lisbon, Andreas Ditsche, chief executive of iGaming.com speaks to Affiliate Leaders on how marketers in the industry can future-proof their businesses.

Please explain the difference between single-jurisdiction affiliates and multi-market SEO?

The difference lies in complexity and in risk allocation. A single-jurisdiction affiliate is essentially putting all its eggs in one regulatory basket. If that market changes overnight, as we’ve seen repeatedly across Europe, the business can be severely impacted.

Multi-market SEO is about building expertise, content, and acquisition channels across multiple regulated markets. It allows affiliates to spread risk, transfer know-how, and create operational efficiencies. In today’s environment, diversification is not just a growth strategy; it’s a survival strategy.

To use a gambling analogy: single-market affiliates are betting on one horse. Multi-market affiliates are running the racecourse.

What has changed in the last few years which pushes cross-border funnels to the forefront?

The biggest change is regulatory volatility, generally in the direction of stricter rules for the regulated market. This is frequently accompanied by tax increases.

Ten years ago, many affiliates could build a successful business around one stable market. Today, regulations evolve faster than ever, tax rates change, advertising rules tighten, and search engine algorithms continuously reshape visibility.

At the same time, player behaviour has become increasingly international. Users consume content globally, compare offers globally, and often move between jurisdictions themselves.

As a result, affiliates need scalable infrastructure, shared CRM systems, multilingual content operations, and technology stacks that can adapt quickly when one market becomes less attractive and another opens up.

What are some examples of grey market conversions, and how do they differ from black market conversions for both operators and customers?

Let me be very clear about this distinction. In many cases it does not exist. Often, there are no fifty shades of grey.

Typically, we say a grey market exists where regulation is unclear, incomplete, or simply non-existent. Operators may hold licenses elsewhere, but serve customers in markets where the local framework is still evolving.

Black-market operators, on the other hand, intentionally operate outside regulatory oversight.

When we look at Europe, practically every market is regulated. If an operator does not have a license for a country, say Germany, it can have as many foreign licenses as possible – but operating in Germany is illegal. It is not grey, or dark grey, it is black.

For customers, the difference often comes down to protection. In regulated environments, players have access to dispute resolution, responsible gambling tools, KYC processes, and consumer safeguards. In black markets, those protections may be absent or unenforceable.

The business challenge for the industry is ensuring that regulated offerings remain attractive enough that consumers do not feel compelled to look elsewhere. Customers who select illegal, unlicensed products are not accessible to legal operators and affiliates.

How can affiliates future-proof themselves in an increasingly zero-click environment?

The days of simply ranking a page and waiting for traffic are fading.

Affiliates need to become brands rather than just websites. That means building direct relationships through newsletters, communities, CRM systems, social channels, podcasts, video content, and other owned audiences.

If affiliates cannot provide context, trust, expertise, or entertainment that goes beyond what an AI-generated answer can deliver, the middleman will become obsolete.

Search remains important, but search engines increasingly want to provide answers themselves. The affiliates that thrive will be those who create trust, expertise, and unique value that cannot be summarised in a search snippet.

In other words: if Google can replace you with a paragraph, your problem is not Google. Your problem is the user is happy with just a few lines of text, without scrolling or clicking. You, as an affiliate, must be the search target.

As more countries introduce tighter restrictions, how can affiliates protect themselves as the environment shifts?

First, diversify geographically. And be ready to withdraw from unattractive markets. Second, invest in compliance before regulators force you to. Third, build internal governance structures that allow you to react quickly to regulatory changes.

The most resilient affiliates are no longer thinking like traffic buyers. They are thinking like regulated media companies.

The question is no longer ‘can we do this?’, but increasingly, ‘should we do this?’. That’s usually where long-term sustainability starts.

What do you find are the disparities between industry professionals and the politicians setting the regulatory agenda, and how can these be brought together?

Both sides often share the same objective: protecting consumers. The disagreement usually concerns how that objective is achieved.

Industry professionals tend to focus on channelisation, keeping players within regulated environments.

While the narrative is, this is where players are protected; the truth is also that this is where legal operators can earn money from players.

Politicians often focus on restricting gambling exposure by making gambling less attractive and by restricting advertising.

Regulators, lawmakers and the legal industry should choose their battles wisely. The opponents are illegal operators.

A statement I have heard from a Canadian lawmaker says it all: “We do not have a big red button to stop gambling. Let’s make the best out of it: investments, jobs, tax revenue – in a responsible way.”

More evidence-based policymaking would help. Regulators need access to real-world player behaviour data, while industry stakeholders need to better understand public concerns. The best regulations are rarely written by either side alone.

Which of the upcoming regulations in Europe (or beyond) will pose the biggest challenge for compliance among operators?

The biggest challenge is not any single regulation. It is fragmentation.

Europe increasingly resembles a patchwork of national frameworks rather than a unified market.

Operators and affiliates must comply with different advertising rules, bonus restrictions, affordability measures, data requirements, and licensing conditions in each jurisdiction.

Managing dozens of regulatory variations simultaneously is becoming a significant operational challenge. Compliance itself is achievable. Complexity is what drives costs.

How do affiliates balance reach, compliance and cashflow, and who is building resilient, future-proof revenue rather than gambling on jurisdictions that could vanish overnight?

The most sustainable affiliates balance three factors.

  • Reach: acquiring audiences efficiently.
  • Compliance: maintaining regulatory trust.
  • Resilience: avoiding dependence on any single market or operator.

The strongest businesses are investing in brands, first-party data, diversified market portfolios and rapid adaptability. This means the ability to grow fast where possible, keeping the cost structure flexible and withdrawing from declining markets without hesitation.

What makes the Affiliate Leaders Summit and SBC Summit the most important fixtures of the year? What do you hope to get out of these events?

The industry moves quickly. Only networking and communication allow you to stay ahead of the curve.

Events like SBC bring together operators, affiliates, regulators, suppliers, investors, and technology providers in one place. That’s where trends emerge before they become headlines.

For me personally, the value comes from challenging assumptions. The best insights rarely come from conference stages alone. They come from conversations over coffee, disagreements between experts, and unexpected meetings.

And, if we’re honest, sometimes a three-minute conversation in a Lisbon corridor can save six months of strategic planning.

I have learnt throughout my career and across all industries I have worked in: people buy from people. I strongly believe that this is still true in the age of AI.

Analysing data and understanding market dynamics is extremely valuable. Talking directly to your business partners is priceless.


The Affiliate Leaders Summit is the global home of performance and affiliate marketing. Across three days, affiliates, operators, media companies and technology providers come together to discuss traffic generation, conversion optimisation, SEO, paid media and the commercial strategies shaping the future of affiliate marketing.

Co-located with SBC Summit at Feira Internacional de Lisboa and MEO Arena on 29 September-1 October. Get your tickets here.