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About Dragon Hot
The report assesses black market activity across 28 European jurisdictions, including the UK, Netherlands and Germany. According to estimates across a mature black market ecosystem, 25 operators account for approximately 64% of relevant black market traffic.
Thanks to the “rapid growth of crypto currencies” and globally recognisable branding through marketing and sponsorships, this handful of operators are generating the majority of illegal gambling traffic across Europe.
The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.
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Responsible gambling and treatment services were recurring themes in the parliamentary discussion.
Minister of Environment and Tourism Dr Wynter Mmolotsi called for Botswana to establish a dedicated rehabilitation facility for people experiencing gambling harm. He also suggested that the country consider systems capable of identifying extended gambling sessions, betting patterns and other potential indicators of harmful play.
“In other countries, such systems detect the time taken, every bet placed, how is the game played and thus help to curb addiction,” Mmolotsi said.
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Yet Dan Waugh, partner at Regulus Partners, pushes back against the idea that enforcement notices reveal a fundamentally non-compliant sector.
“Operators failing compliance checks is never a good look,” he says. Campaigners often claim that financial sanctions are priced in and that the Commission should revoke more licences, although Waugh does not believe operators view settlements merely as a cost of doing business.
Nor are regulatory breaches unique to gambling. Waugh notes that Tesco was fined more than £8 million for food hygiene failings in 2021, without parliamentarians demanding that it should be prevented from selling cornflakes.
