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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.
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The order was short-lived. The commercial court of appeal granted a stay on 26 January. According to Medias24’s 12 February report, it then annulled the order and rejected MDJS’ claim, ending the daily penalty. MDJS could still appeal.
The court action came as MDJS was warning of the financial impact of offshore betting. Director General Younes El Mechrafi told a parliamentary sport forum in December that illegal sports betting stakes reached about MAD3.5 billion in 2024. He put the cost to the state at some MAD700 million, split between the national sports development fund and the Treasury.
Meanwhile, Tunisian gambling law rests on Decree-Law 74-20 of October 1974. The only lawful sports betting channel is the state company Promosport. Pari-mutuel horse race betting is managed by the Agence Tunisienne de Solidarité.
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The study highlighted significant gaps between operator disclosures and genuine player comprehension.
The Commission’s investigation into what constitutes “informed choice” in gambling involved a multi-method approach.
Researchers conducted a rapid desk review of 53 relevant sources, three deliberative focus groups segmented by gambling product type (sports betting, online casino/slots and land-based gambling) and four in-depth interviews with people identified as being at higher risk of harm (Problem Gambling Severity Index (PGSI) score of 8 or more).