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One such rule was for licensees that had faced compliance enforcement during the five years operating in the Netherlands.

At the time KSA announced: “Providers that made mistakes in the past five years must explain during the application process how they have learned from previous mistakes and how they intend to prevent recurrence. If we find this explanation insufficient, the permit may be denied or additional conditions and restrictions may be imposed.” 

This requirement raised concerns among operators worried that the barriers to entry could have become more restrictive, But at a meeting on the policies last year the regulator assured licensees it was not enforcing a specific strict rule on this.

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In all three, private online betting has no licensing route. Governments are tackling offshore demand through blocking, prohibition and criminal enforcement.

The contrast with land-based gambling is striking. Casinos in Morocco and Egypt operate within recognised frameworks and, in Morocco, attract international investment. Private online betting remains outside the legal market.

The scale of that unlicensed market is unclear. MDJS’ own estimate of about MAD3.5 billion a year is the only figure available. No comparable public estimate exists for Tunisia or Egypt.

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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.