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“It’s not a dark alley,” he continues. “It’s a large operator that’s regulated in other places, so it’s not the risk for the player that sometimes is implied.”

With the central challenge of tax to compete with, operators face a test of whether they can maintain growth while remaining competitive in an increasingly fierce market.

Escobar expects the competitive landscape to evolve as the market settles, with operators facing a different set of priorities from those that defined Peru’s initial regulatory rollout.

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Dahms highlighted the significant dangers unlicensed operators pose to player protection and the overall integrity of the licensed market. He cited the absence of controls such as deposit limits, identity verification and player suspension tools. 

He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”

The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

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“We finally got to a point where we said, you know what, let’s drop all our other efforts right now and get these over the finish line and get them up for comment so that we can make sure that we’re current with things,” Jeremy Eberwein, chief of the board’s Technology Division, told iGB.

The bulk of the work revolved around compiling and codifying the technical information in one place, Eberwein said. There were some existing Technical Standards, but other requirements lived in the state’s Minimum Internal Control Standards, which are a broad mix of technical and procedural requirements.

The goal is to make it easier for licencees to find technical information in one definitive source rather searching across multiple libraries. Most of the explanatory notes in the revisions refer to adaptations from MICS and other sources. This process has been years in the making, Eberwein said, with work stopping and starting at various points.