If they had to be removed....
If a problem is too big, then break it down. You don't have to enforce every code on every site, just have the ability to enforce some of them. Random drugs testing works on the basis that you could be tested at any time, so you better stay clean all the time. So how about randomised code testing?
If all the networks keep spreadsheets/databases of codes and expiry dates they can pick some that expired a week ago, bung them into google with the merchant name and away you go. i.e. a search for the expired code DISH35 would be "dixons code DISH35" and Google comes up with
Google Search for 'dixons code DISH35'
There can't be that many codes expiring on any one day, and it would be fairly simple to see who the repeat offenders are after a few days. If they keep on breaking the rules then boot them off the program or network.
If google isn't turning up great results because of caching, then get the code spreadsheet or database to produce the list and test on a random sample of sites.
Once the sites that hit the top positions in the serps get the idea and are playing by the rules, the lower positioned sites will come to the fore and get the same analysis.
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