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Moreover, Evolution had continued earning revenue from operators in so-called grey markets without enforcing contractual blocks or other remedial measures despite earlier allegations.
Last month the UK Gambling Commission agreed a regulatory settlement with Evolution of £4.75 million, after finding its games had been accessible via a handful of unlicensed operators in the UK.
In July the Commission said its investigation had discovered the supplier had failed to maintain adequate anti-money laundering and customer due diligence controls in the UK.
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Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.
The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.
The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators.
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When asked which operator will be willing to take the risk and ultimately win Japan’s next “licence lottery”, Klebanow contends that it depends on how restrictive – or attainable – the regulations and requirements imposed by the government will be.
“If policymakers once again impose onerous policies that limit a property’s profit potential, then most developers will not take the risk of investing upwards of $10 billion in an IR development,” says Klebanow.
One exception, he notes, could be the Seminole Tribe of Florida and their proposed Hard Rock Resort Casino in Tomakomai, Hokkaido.