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It had sent over 217,000 marketing emails and SMS messages within a 16-day window to customers who had explicitly unsubscribed. ACMA regarded the volume and timing of these messages as significant enough to warrant enforcement action. 

In response to the penalties, Dabble Sports has agreed to a two-year court-enforceable undertaking. It has obliged the company to commission an independent review of its compliance systems. Dabble must develop a board-approved plan to implement these changes with appropriate resources.

An ACMA spokesperson reiterated: “BetStop is an important consumer protection measure, but it only works if wagering companies follow the rules.” 

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Much of the onus for the increasing black market is put on increasingly restrictive policies enforced by regulators across the licensed sector.

Taking a deeper look at these restrictive driving black market activity, up to 46% of the markets covered in the report enforced “significant advertising restrictions” on the regulated market, including in Belgium, Bulgaria, Coratia, Cyprus, Germany, Italy, Latvia, Lithuania, Montenegro, the Netherlands, Poland, Romania and Spain.

Additionally the report cited taxing consumers (in 29% of the 28 markets covered), and banned products (14%), were also propelling growth in illegal gambling. A lack of choice, due to monopolies in place in five markets has also driven the rise.

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While thousands of new casino games reach the market every year – with research suggesting the number of releases is growing by around 10% each quarter – volume does not necessarily equate to variety. Developing something genuinely different means taking a risk, while the industry’s familiar practice of reskinning existing games, or adapting mechanics and concepts that have already proved successful, offers a much safer commercial proposition.

For James Curwen, chief executive at Yggdrasil, the tension between the industry’s need for fresh content and the commercial realities of producing it goes to the heart of the challenge.

“The industry has a content problem,” he says. “There are thousands of games being released and too many of them are variations of something that already exists.