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“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

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.

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What else can Netherlands gambling operators do to stop the flow of players offshore? Holland Casino is a member of online gambling trade association VNLOK which represents 90% of the licensed operators, and Petra answers simply: “If we knew the answer, we would try to reach it.

“What I do think is that deciding together, not only as operators, but together with politicians and stakeholders, that a legal market is very important to get that done. We’re not there yet, and that’s what we’re saying.

“An unregulated market doesn’t become a safe market. People will always gamble, so we have to make sure that we have a strong legal market. And so you also need to give us some room to exist. And of course, we need to be regulated. A regulated market is always better than an illegal market.”

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The regulator noted that several operators received “additional points for attention”, indicating that while these applicants met minimum legal thresholds, the KSA expected continuous improvements in compliance practices.

In June, one of the operators, TOTO online BV, was reported for violating the ban on featuring role models in advertising materials.

This was not the first time TOTO has been in trouble with KSA. The platform was fined in 2022 for a similar endeavour – gambling advertisements that were seemingly aimed at young people.