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Speaking of which, in Holland the casinos must have two databases, one for online players, one for land-based, and keep them very separate – except for when it comes to responsible gambling (RG). A casino can’t use its online offering to promote the land-based side to players, and vice-versa – but the data can all be used together to make sure customers are safe from harm whenever they play with the same operator, online or otherwise.

Being a state-owned monopoly is beneficial for RG purposes. You don’t have an employer or shareholders expecting a positive quarterly earnings report four times a year, and as long as the business is self-supporting it can continue to make the best choices for player health and relationships. As Petra defines it: “It’s about a healthy long-term relationship.”

Holland Casino has a responsible gambling board, which includes scientists, experts with lived experience and their own RG executives. They meet with the board every few months to talk over current processes, and the board challenges the operator’s ideas and implementations, pushing them to do better.

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FATF released the report – Risks of Gaming and Gambling – on Wednesday. It updates the body’s 2009 analysis of the casino sector. In addition, it draws on questionnaire responses from 80 jurisdictions and written comments from a further 29, alongside industry consultation.

The report identifies land-based and online casinos and sports betting as carrying the highest money laundering exposure. By contrast, lotteries and scratchcards present lower risk. 

It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.

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For enforcement authorities, however, the challenge is not simply estimating its size. It is keeping track of an ecosystem that can continually change domains, infrastructure and acquisition channels. That is where Madsen sees Trace2Trace fitting in.

One of its investigations concerns a specific globally renowned brand. Madsen says an initial scan identified around 1,600 domains, followed by another roughly 4,500 associated with this operator. That puts the number identified so far at around 6,000, although he believes the actual figure is considerably higher. “I think what we’ve found so far is only a small part of the overall picture,” he says. “I’m almost certain the real number is at least twice as high.”

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.