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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.

Much of the onus for the increasing black market is put on increasingly restrictive policies enforced by regulators across the licensed sector.

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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, 

Much of the debate focused on stricter supervision and the protection of players. Ultimately, the secretary of state said that work to increase black market enforcement would take precedent in the Netherlands, while increasing the gambling age would be revisited once the illegal market is under control.

“It is time to tackle that illegal offer properly, so that we can move towards a time when we do have to move towards an age increase. If that turns out not to be necessary, then we don’t do it,” she said.