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The report’s authors noted that VIP managers “are not asking to be replaced” but desire tools that assist by triaging and pointing out priority players, while humans maintain relationship control and make final decisions.

Respondents identified several priorities for improving VIP operations. These included an integrated system combining player data, communication history and task management. 

Respondents also requested structured and consistent guidelines with key performance indicators aligned to relationship outcomes. Real-time, detailed data alongside predictive behavioural signals also came up as a frequent answer.

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“Tackling illegal gambling requires joint responsibility from banks, payment providers and hosting services who facilitate these platforms.”

The lottery operator also criticised government proposals for a blanket advertising ban on licensed online gambling providers in June. It argued such restrictions could inadvertently drive more players towards unregulated, illegal platforms.

According to Nederlandse Loterij, illegal operators currently control approximately half of the Dutch online gambling market and account for roughly 95% of online gambling advertisements, frequently masquerading as licensed providers. 

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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.