Moo Moo Cow

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“They lose quicker, dry up quicker, recruitment or re-recruitment,” he says. “If the recruitment of players dries up, then what are you going to do? Definitely there can be components like that.”

For now, the growth provides room for multiple market makers. Marantelli expects margins to “stay good during the growth period” before contracting as competition intensifies. The more complex RFQ and parlay markets may offer the best protection against that compression.

The result is an emerging ecosystem that looks less like millions of customers casually trading predictions with one another and more like an outsourced sportsbook trading room. Exchanges own the platform and recruit the customers; specialist firms price the risk and provide the money needed to make those markets function.

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Yet Dan Waugh, partner at Regulus Partners, pushes back against the idea that enforcement notices reveal a fundamentally non-compliant sector.

“Operators failing compliance checks is never a good look,” he says. Campaigners often claim that financial sanctions are priced in and that the Commission should revoke more licences, although Waugh does not believe operators view settlements merely as a cost of doing business.

Nor are regulatory breaches unique to gambling. Waugh notes that Tesco was fined more than £8 million for food hygiene failings in 2021, without parliamentarians demanding that it should be prevented from selling cornflakes.

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The Loterij suggested around 200,000 Dutch citizens already engage with unauthorised platforms.

Earlier this summer, the Dutch Online Gaming Providers (VNLOK) trade body initiated legal action against Meta and lodged a formal complaint with the European Commission, accusing the social media giant of failing to prevent the widespread display of illegal online gambling advertisements targeting Dutch users on Facebook and Instagram. 

According to VNLOK, the illegal online gambling market in the Netherlands now matches the size of the regulated sector, with estimated annual revenues in excess of €1 billion ($1.1 billion).