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“People will lose money faster on exchanges for lots of reasons,” Marantelli says. “It inherently increases spend, volatility, lots of things. And you’re playing against a sharper audience than you’re playing against at the DraftKings sportsbook.”

He compares the effect with sportsbook cash-out features, which gave customers more apparent control over their bets but may also have encouraged greater spending. The crucial difference is that an exchange customer can be facing a specialist whose entire business is identifying inaccurately priced contracts.

Kendrick sees a warning in the history of betting exchanges. In their early growth phase, there was sufficient retail liquidity for numerous market makers to profit. As that retail pool weakened, the sharper firms increasingly found themselves trading against one another.

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They have also been advised to thoroughly review their Know Your Customer, fraud detection protocols and contractual terms to reflect the guide’s recommendations. 

They must also evaluate their current technical safeguards to ensure alignment with regulator expectations and certification standards.

Safeguarding has reappeared as a focal point for the regulator. In July of this year, ANJ imposed a €500,000 ($572,797) fine on an unnamed online betting operator, referred to as Company X, for not adequately identifying and supporting customers exhibiting signs of problematic gambling. 

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The appeals court did not rule that Baldwin or Bridge Capital owes Laos the money. Instead, it said the lower court must hear Laos’ argument that they should be responsible for awards made against the companies they allegedly controlled.

That sends the sprawling Savan Vegas dispute back to court once again, 14 years after it began.

Laos attorney David Branson told Law360 the government has been trying to collect the awards for more than seven years and said the latest ruling had cleared a “path to recovery.”