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“They challenge us both from an academic side and a more practical side. We try to develop our rules as we go along but you have to prove every single day that you’re doing all that you need to do on responsible gaming,” Petra notes.

The Netherlands online gambling market has been the subject of many column inches and much speculation thanks to regulation that has been largely described as heavy-handed and perhaps a little short-sighted – even by the country’s own regulator.

The triumvirate of Netherlands, Germany and Sweden is often held up as an example of how not to regulate, with all three countries haemorrhaging players to waiting illegal operators. So what is public sentiment like towards operators? “My feeling is that if you look at public sentiment, they don’t see really the difference between online and land-based,” says Petra. “If you look into what they’re saying, they’re primarily talking online. But for the general public, there is no difference [between the channels] in that respect.”

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Beyond offering crypto payment solutions, a number of black market operators are licensed in “light touch” offshore jurisidictions which use opaque offshore operating structures to help to obscure company ownership and make local enforcement against these companies complex, the report noted.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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

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The ASA reviewed a clip posted to TikTok in July promoting Midnite, a Gibraltar-based online casino app. The clip displayed a young-looking man using the app, accompanied by the voiceover: “Another massive World Cup upset. Bet £10 on the big match and get £30 in free bets. Level up your World Cup with Midnite, get on it.”

According to the ASA’s Code for gambling advertising, anyone who “was, or seemed to be, under 25 years of age” must not be depicted gambling or playing a significant role in advertisements. 

The regulator concluded that the central figure’s youthful facial features, casual styling and excited demeanour gave the impression he was in his late teens or early twenties.