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While the intention is to protect vulnerable households and ensure welfare is spent on essential needs, proposed measures are being complicated by legal, technical and privacy obstacles.

Harris Tsangarides, executive director of the Gaming & Casino Supervision Commission, said his department had noticed spikes in gambling activity coinciding with GMI payment dates, prompting the regulator to consider “technical solution” to cross-reference GMI beneficiary lists with casino membership records.

An issue raised by Giannis Vasiliadis, director of WBAS, was the limited access to recipients’ banking information. This limited data can hint at suspicious activity but cannot conclusively verify gambling transactions.

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The bulk of the work revolved around compiling and codifying the technical information in one place, Eberwein said. There were some existing Technical Standards, but other requirements lived in the state’s Minimum Internal Control Standards, which are a broad mix of technical and procedural requirements.

The goal is to make it easier for licencees to find technical information in one definitive source rather searching across multiple libraries. Most of the explanatory notes in the revisions refer to adaptations from MICS and other sources. This process has been years in the making, Eberwein said, with work stopping and starting at various points.

“We had various iterations of the drafts internally probably going back at least a decade, and just never made it to the finish line for various reasons,” he explained.

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Thanks to the “rapid growth of crypto currencies” and globally recognisable branding through marketing and sponsorships, this handful of operators are generating the majority of illegal gambling traffic across Europe.

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%.”