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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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Last week a committee made up of MPs from across the Netherlands’ political spectrum also raised concerns around the role of Meta and Google in supporting the black market.
Candidates from the VVD party urged the government to take a “harder stance” against these big tech platforms.
Van Bruggen told the gambling committee that both Meta and Google were open to maintaining a dialogue with the government on this.
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He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.
“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.
The “too easy to get a licence” argument doesn’t necessarily hold up to scrutiny, to be fair. Andrew Bentley, co-founder and CEO of regulatory technology startup LiSense, is one who rejects the suggestion.
