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Another point of contention was content marketing and influencer promotions. The Lords committee advised treating this as advertising and, if a full ban were not immediately feasible, prioritising its prohibition.

Sponsorships and advertising with sports teams was also flagged as according to the report, voluntary efforts had failed to reduce the industry’s exposure. 

With int he report Dr Matt Gaskell MBE observed that “overall exposure (including shirts, hoardings, logos, sponsorship and related marketing) during live sports programmes does not show that self-regulation has reduced exposure meaningfully”. 

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In addition to illegal gambling, investigators suspect extensive tax evasion, with a projected tax shortfall of about €77.6 million for 2024.

The DSWV, representing licensed sports-betting operators, broadly welcomed the law enforcement action as a necessary response to the illegal market’s growth and associated risks. 

“This successful investigation clearly demonstrates the scale that the illegal gambling market has now reached,” said Mathias Dahms, president of the DSWV.

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Enforcement publicity may lack context, and some settlements may involve errors rather than systemic recklessness. But the sector cannot control how its opponents use these cases. It can only reduce the supply.

At a moment when the industry needs to persuade politicians that regulated gambling is capable of managing risk responsibly, repeated failures in long-established areas such as AML and safer gambling amount to political self-harm.

The Commission may sometimes load the gun, but operators keep providing the ammunition.