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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.
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The research, published by The Intercept Brasil on Monday, analysed more than 55,000 Instagram accounts and cross-referenced the results with the official list of authorised operators from the Secretariat of Prizes and Bets (SPA).
According to the survey, the problem arises when a user follows a single account related to betting. The platform’s recommendation system then starts showing other profiles in the same segment, including betting sites, influencers and specialised pages.
Among the 100 most recommended profiles are accounts that, together, have accumulated more than 6 million followers and 114,000 posts. There are three main types of profiles recommended by Instagram: operators, content creators and media specialising in the betting market.
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The gap comes as Phnom Penh prepares to host its major anti-scam conference on 23-24 September, part of the wider government campaign against online scam networks.
Initially framed as “Together Towards Disrupting the Chain and Ending Online Scams” by AKP in August, the conference now carries the theme “Acting Together towards Breaking the Chain and Eradication of Online Scams” on its official website.
Prime Minister Hun Manet has publicly characterised the crackdown as an effort to “clean our house” and restore Cambodia’s reputation internationally.