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“In my experience, where compliance concerns can be satisfactorily addressed without suspending an operator’s licence, the Commission may allow the operator to implement remedial measures or an action plan while continuing to trade,” says Richard Williams, partner at Keystone Law, speaking before the news of the collapse of the businesses.
“The fact that suspension has been considered necessary in this case therefore indicates that the Commission presently considers the issues sufficiently significant to justify preventing the operators from continuing to offer gambling while its reviews are ongoing.”
For any consumer-facing businesses, a suspension is likely existential and such appears to have been the case here. But wider implications have to be considered before the two sites are binned forever.
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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.
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The crackdown on illegal gambling sites coincided with a broader policy debate in The Hague. The Dutch House of Representatives is set to discuss gambling regulation reforms this week.
Nederlandse Loterij has welcomed government proposals aimed at expanding the Gambling Authority’s powers to combat illegal operators but has cautioned that comprehensive legislative changes could take years to become effective.
Blok called for more decisive immediate action, saying: “The government must act now through criminal prosecutions by the Public Prosecution Service, alongside measures taken by regulators and licensed operators.
