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The text also bans exploiting situations of economic crisis, unemployment, debt, emotional distress, grief, anxiety, depression, loneliness, or other conditions of vulnerability to attract, retain or reactivate gamblers. 

Operators must maintain permanent mechanisms for age verification, self-exclusion, voluntary time and wagering limits, and information on the user’s own gambling behaviour. Self-exclusion must be effective with all authorised operators. 

The text also prohibits bets placed using credit cards, the use of predictive models to identify moments of greater vulnerability, and platform design mechanisms that hinder a conscious decision to stop betting, leave the service, or activate limits and blocks. Operators must maintain permanent alerts about compulsive gambling, indebtedness and asset loss, and adopt verifiable protocols for identifying risky behaviour.  

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Notably for highly engaging verticals light online slots, if players are receiving a smaller-than-expected RTP (return to player), or bonuses have been restricted, they could again transition to an illegal offering where there are no such restrictions.

As has been flagged in previous reports, Regulus highlighted that the top 1% of active customers accounts for almost 50% of black market revenue across Europe. This follows a similar trend across licensed gambling as the report highlights “online gambling is a consumer discretionary expenditure item. This means a large proportion of expenditure is concentrated into a relatively small number of players.”

In its market-specific breakdown, the report noted a “rapid reduction in channelling” in the UK, following the increased use of affordability checks.

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Ben Robinson, managing partner at Corfai, argues that the American listing achieved what it was supposed to achieve. The problems came afterwards. “The question was which arm of the K-shaped market Flutter would end up on. We have the answer now. Capital is concentrated in a narrow band of technology names and everything else is being marked on earnings.”

A US listing can improve access to capital without making the underlying business more attractive. London has a capital-markets problem. Gambling has an investment problem. The two overlap, but they are not the same thing.

Frank Fantini, founder and publisher emeritus of Eilers-Fantini, thinks the change began before Covid. “There is a tendency to look at the world as pre-Covid and post-Covid,” he says. “But the decline in gaming began earlier than that with the slowdown in new jurisdictions and new projects.”