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FATF’s warning on illegal and offshore gambling will resonate in Denmark. Last year, Spillemyndigheden secured a court order to block 178 unlicensed gambling sites, the largest such action in the regulator’s history. 

The case highlighted how illegal operators disguise their presence through multiple site variations, a tactic the FATF report also flags as a red flag indicator. 

Denmark’s approach reflects a wider pattern that FATF has tracked for years through its own grey and black listing system. Under this system, jurisdictions with weak AML/CTF controls face increased monitoring or reputational sanction.

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“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.

By comparison, the long tail of smaller black market sites rely heavily on affiliates to generate traffic.

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Miller served on the forum for several years and was a key UK figure during a period when the Gambling Commission implemented extensive reforms to online gambling regulation and affordability checks. GREF expressed its gratitude for Miller’s contributions during his tenure.

Jean-Michel Costes has also left the board after concluding his role at France’s Autorité Nationale des Jeux (ANJ). 

Costes was involved with GREF at a time when numerous European regulators, including the ANJ, focused on tightening advertising regulations and boosting player protection frameworks. The forum thanked Costes for his dedicated service.