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In any event, successive regulatory tightening and tax increases have already created a “reasonably effective deterrent” to market entry.

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.

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This will enable them to continue legal operations in the Netherlands from 1 October 2026 through to 30 September 2031. 

It is the first time since the market was launched in 2021 that licences have come up for renewal and whomever is on the final list will indicate how many operators have decided not to remain in the market.

The initial 2021 licences are set to expire at the end of September 2026. All licence holders were required to submit applications for the subsequent five-year period, covering 2026 to 2031.

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“Kugler’s position is that Evolution does not supply games to Iran. He stated that “I know we have players in Dubai”, Spectrum notes, in response to Black Cube’s claims.

Another claim made by Black Cube’s report was that Evolution had accepted wagers in virtual currencies and cash. Spectrum confirms that wagers were made by end users using crypto currencies, however it was the operator, and not Evolution accepting these bets.

After assessing part of a 75-page PDF spreadsheet of transactions provided by Evolution, Spectrum found crypto wagers had been placed on Evolution games provided by Hub88, as alleged by Black Cube.