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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.

Madsen says investigators can also examine how sites appear from different jurisdictions. If a site is presented in a country’s local language, for example, that can indicate that the market is being targeted. The next question is whether the operator has the necessary licence.

The same intelligence can be useful to gambling companies and suppliers that want to monitor where their products are appearing. Madsen says Trace2Trace currently has a client that fits that description, although he cannot disclose its identity.

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She emphasised that half of Entain’s retail employees were women, with over 50% working flexible or part-time hours. More than 2,500 of its employees are under 25 years old.

The letter argues that the proposed increase would hit the workers and communities Labour’s “Makerfield Test” is supposed to protect, while potentially costing the Exchequer money rather than raising it.

Entain stressed the importance of its retail networks in providing local employment and community engagement. 

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The report rejected argumentswarning that advertising restrictions would drive consumers to illicit gambling sites. They citied weak evidence for mass migration to illegal operators following advertising limits. 

“Interviews [ … ] with representatives of state monopoly operators across European jurisdictions consistently suggested that advertising restrictions did not lead to consumer migration towards illegal operators,” the report said. 

This report arrived amid the UK government’s 2023 white paper on gambling reform, which introduced a statutory levy for funding research and treatment.