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Dahms highlighted the significant dangers unlicensed operators pose to player protection and the overall integrity of the licensed market. He cited the absence of controls such as deposit limits, identity verification and player suspension tools.
He also called for continued rigorous enforcement efforts alongside strict regulation to safeguard consumers, adding: “Anyone who wants to strengthen player protection must therefore consistently crack down on illegal services and strengthen legal ones.”
The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.
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The three markets have reached the same point by different routes. Morocco has an incumbent defending its exclusivity through the courts, so far without success.
Tunisia has competing bills to prohibit or regulate online betting, neither of which has advanced. Egypt has relied on enforcement measures.
In all three, private online betting has no licensing route. Governments are tackling offshore demand through blocking, prohibition and criminal enforcement.
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The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.
Operators were encouraged to take several practical steps, including enhancing terms and conditions, maintaining robust evidence and uptaking technical standards.
They have also been advised to thoroughly review their Know Your Customer, fraud detection protocols and contractual terms to reflect the guide’s recommendations.