US Black Market GGR Report and the 74% illegal claim

The US Black Market GGR Report has landed like a cold splash of water on a debate that many US stakeholders thought was moving in the right direction. According to a new Campaign for Fairer Gambling briefing using analysis from Yield Sec, illegal and unregulated operators captured 74% of total US online gross gambling revenue in the first half of 2025, even as regulated markets continued to expand.

That single headline number matters because it reframes the narrative. The question is not whether online gambling is growing in the United States. The question is who is capturing that growth, and what it says about consumer behavior, enforcement, and the design of regulated offerings.

What Yield Sec and the Campaign for Fairer Gambling claim in the report

The CFG USA National 2025 First Half Special Briefing, released on 8 January, says the total US online gambling marketplace was worth $52bn in H1 2025. Of that, $38.7bn was attributed to illegal gambling activity.

The report also states that the gross gaming revenue split held steady from full year 2024 into the first half of 2025, at 74% illegal and 26% legal. In other words, even if legalization has expanded access in some states, the illegal sector has not been displaced in aggregate terms, at least according to the briefing.

Ismail Vali said legalisation alone will not remove or reduce unregulated gambling, arguing that legislation needs monitoring, policing, enforcement and optimisation.

Crypto gambling is flagged as a major accelerant

One of the most striking elements in the CFG and Yield Sec findings is the role attributed to crypto gambling. The report describes this as a rapidly growing segment, accounting for 28% of total USA marketplace GGR and 37% of illegal only GGR.

In raw revenue terms, the report puts crypto gambling GGR at $14.4bn for the six month period. For regulators and licensed operators, the implication is clear. The market is not only contending with traditional offshore style offerings, it is also dealing with a category the report portrays as scaling quickly and capturing meaningful share.

The search and discovery problem is not just marketing, it is market structure

Beyond the topline GGR split, the report claims something that speaks directly to how players actually arrive at online gambling products. It found that 82% of what audiences see when they look for online gaming across the US ecosystem is promoting illegal unregulated gambling.

This matters because discovery is where regulated operators often assume they have an advantage. In practice, the briefing suggests the opposite, illegal offers may dominate visibility, which can distort consumer choice before brand, licensing status, or safer gambling tools even enter the conversation.

If the report is directionally correct, it also helps explain why legalisation alone may not shift behavior. Players cannot choose regulated options if their first exposure is overwhelmingly illegal promotions.

Why the 74% claim is so politically and commercially consequential

Regulated markets tend to justify themselves on a few familiar pillars, consumer protection, channelization, and public benefit through taxation and oversight. A claim that nearly three quarters of online GGR is illegal challenges the core channelization promise, and it does so at a national scale rather than a single state snapshot.

For the industry, it raises a difficult strategic question. If the illegal sector is capturing the majority of revenue in aggregate, then the regulated sector is competing not merely on product quality, but on the entire environment that shapes demand, including compliance costs, advertising constraints, and friction in onboarding.

For policymakers, it puts pressure on whether existing frameworks are delivering what voters were promised. That tension is visible in Derek Webb’s statement, where he argues there is still no evidence of meaningful action against the black market at state or federal level, and that illegal operators continue to share in growth as the total market expands.

MPEO as the report’s prescription for taking back control

Ismail Vali frames the response using a specific operational lens. He argues that the path forward must impact policy, process and practice through what he calls MPEO, Monitor, Police, Enforce and Optimise.

That framework is not presented as a one off crackdown. It is presented as an ongoing cycle, suggesting that unregulated gambling is adaptive and persistent, especially when incentives remain high and the pathways to consumers remain open.

In practical terms, the briefing’s logic implies that legalization is the foundation, but not the finish line. Without continuous monitoring and enforcement, the market can become bifurcated, with legal operators carrying the burden of compliance while illegal operators capture discovery channels and price sensitive demand.

What this means for the regulated industry narrative

There is a common assumption that regulated expansion naturally squeezes illegal competition. The CFG and Yield Sec briefing argues the opposite outcome has occurred, at least at the national level across the period it analyzed, with the market growing and illegal operators continuing to claim the majority share.

That is uncomfortable, but it is also useful, because it points to where the next phase of US iGaming strategy may need to focus. Not simply on passing bills, but on building a functioning competitive environment where legal operators can actually win attention and trust at the moment consumers make choices.

From a consumer standpoint, the report implicitly raises a safety question. If most GGR is flowing to unregulated operators, then many players may be outside the guardrails that regulated markets typically emphasize.

Key takeaways from the US Black Market GGR Report

• Illegal operators captured 74% of total US online GGR in H1 2025 according to the CFG briefing using Yield Sec analysis,
• the report values the total US online gambling marketplace at $52bn for the six month period, with $38.7bn labeled illegal,
• crypto gambling is described as rapidly growing, accounting for 28% of total marketplace GGR and 37% of illegal only GGR at $14.4bn,
• the briefing claims 82% of what audiences see when searching for online gaming promotes illegal unregulated gambling.

Where the debate goes next

The US Black Market GGR Report is ultimately a challenge to complacency. If the majority of revenue is still being captured outside regulation, then the conversation has to shift from whether legalization is happening to whether the regulated ecosystem is being protected and made competitive.

Whether stakeholders agree with every figure or not, the report’s core message is hard to ignore. The illegal market is not a fading legacy problem, it is a live, evolving competitor. And as the briefing argues through its focus on monitoring, policing, enforcement and optimisation, the response has to be just as continuous and adaptive.