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The bulk of the work revolved around compiling and codifying the technical information in one place, Eberwein said. There were some existing Technical Standards, but other requirements lived in the state’s Minimum Internal Control Standards, which are a broad mix of technical and procedural requirements.

The goal is to make it easier for licencees to find technical information in one definitive source rather searching across multiple libraries. Most of the explanatory notes in the revisions refer to adaptations from MICS and other sources. This process has been years in the making, Eberwein said, with work stopping and starting at various points.

“We had various iterations of the drafts internally probably going back at least a decade, and just never made it to the finish line for various reasons,” he explained.

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Using data collected primarily through Chrome’s incognito mode to exclude personalised search histories, the KVA identified several autocomplete and pre-fill search queries that directly suggested illegal gambling platforms to users.

Examples included phrases like “online casino zonder Cruks” (online casino without CRUKS, the Dutch self-exclusion registry for problem gamblers) and “beste online casino buitenland” (best online casino abroad).

KVA expressed concern over the potential manipulation of Google’s autocomplete function by unauthorised operators and websites primarily set up to redirect Dutch consumers to illegal gambling offers.

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But he acknowledges the possibility that faster customer losses could eventually test the sustainability of the model.

“They lose quicker, dry up quicker, recruitment or re-recruitment,” he says. “If the recruitment of players dries up, then what are you going to do? Definitely there can be components like that.”

For now, the growth provides room for multiple market makers. Marantelli expects margins to “stay good during the growth period” before contracting as competition intensifies. The more complex RFQ and parlay markets may offer the best protection against that compression.