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Within the report, Spectrum alleged “concerns around the availability of Evolution’s games in certain prohibited markets, the regulatory implications of its practices, and the lack of proactive monitoring of its customers”.
However the report confirms that Spectrum did not believe Evolution had engaged in any illegal practices.
iGB is publishing the full 69-page report, which is accessible to registered users of the New Jersey court system, below for anyone to read.
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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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“Some of them [investors] that were looking at Japan were looking at a big IR licence or nothing. With Tokyo and Yokohama being out of the mix, maybe some weren’t as interested anymore and decided to sit back, and wait and see how regulation and licensing shake out.”
One concern for operators is “the short duration of licences and renewal of licences”, notes Leckert. For operators, the casino business licence is renewable every three years, while the IR development-plan authorisation runs for 10 years, in contrast to the 18-year IR licence term in the Philippines, for instance.
Limiting the duration of licence validity “puts the entire capital investment at risk”, says Klebanow. Further regulations, including limiting residents to 10 visits per month and requiring them to present a ‘My Number Card’ when gambling, further erodes project viability. “Ultimately, casino developers individually concluded that developing an IR was too risky, and they took their billions of dollars in potential capital investment and walked away,” observes Klebanow.
