Tapinata

What is Tapinata?

On Wednesday the UK’s Advertising Standards Authority (ASA) ruled against Midnite following an investigation into a paid TikTok advertisement featuring an AI-generated character who appeared to be under the age of 25 and engaging in gambling activity. 

The ASA reviewed a clip posted to TikTok in July promoting Midnite, a Gibraltar-based online casino app. The clip displayed a young-looking man using the app, accompanied by the voiceover: “Another massive World Cup upset. Bet £10 on the big match and get £30 in free bets. Level up your World Cup with Midnite, get on it.”

According to the ASA’s Code for gambling advertising, anyone who “was, or seemed to be, under 25 years of age” must not be depicted gambling or playing a significant role in advertisements. 

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For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.

One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”

Euromat’s report has suggested that a core group of 25 offshore operators are generating up to 64% of European traffic to the black market.

What is Tapinata?

Further bets flagged by operators involved other politically sensitive individuals, including Metropolitan Police officers and political advisers. The Commission charged 15 people total in April 2025. Four have now pleaded guilty.

The offences relate to special betting markets that let customers wager on the exact date of the general election.

The then-prime minister, Rishi Sunak, announced 4 July 2024 as the election date on 22 May 2024. However, internal planning for that date had already begun at 10 Downing Street and Conservative Campaign Headquarters before the announcement.