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The report also cites brands targeting a specifically banned vertical or product within a jurisdiction as driving black market activity. While markets across Europe have many examples, one such flagged in the report is that iGaming remains illegal for licensed operators in France.

“The largest black market operators have scaled to create recognisable brands with traffic that can compare to domestically licensed operators,” the report’s authors wrote. “The top group of sites by common owner has a 12% share of traffic, while the largest single brand has 10%.”

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.

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Respondents identified several priorities for improving VIP operations. These included an integrated system combining player data, communication history and task management. 

Respondents also requested structured and consistent guidelines with key performance indicators aligned to relationship outcomes. Real-time, detailed data alongside predictive behavioural signals also came up as a frequent answer.

Managerial autonomy supported by senior leadership was also mentioned by respondents.

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As well as a statewide exclusion register, the package also set out to reduce the number of poker machines from the current figure of 87,000 across 2,100 clubs and hotels. 

The government said it aims to achieve this by increasing the forfeiture rate when gaming machine entitlements are traded from one in three to one in two. 

The NSW government initiated its first formal review of ClubGRANTS in over a decade after taking office in 2023. Although the final report was submitted in January 2025, it has yet to be released publicly.