Empty The Bank

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They must also evaluate their current technical safeguards to ensure alignment with regulator expectations and certification standards.

Safeguarding has reappeared as a focal point for the regulator. In July of this year, ANJ imposed a €500,000 ($572,797) fine on an unnamed online betting operator, referred to as Company X, for not adequately identifying and supporting customers exhibiting signs of problematic gambling. 

The fine followed an investigation that found Company X had failed to correctly identify 29 high-risk players at an appropriate risk level. Six players were missed entirely and 23 were misclassified at a lower risk tier. 

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There is a second complication. The relentless flow of Commission statements may eventually make enforcement less damaging rather than more.

“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.