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“You shouldn’t necessarily need 100 people and millions of euros of infrastructure to have a great idea and turn it into a successful slot,” Curwen says.

Lower barriers to entry could significantly widen the pool of potential game creators. Curwen sees opportunities not only for established and emerging studios, but for operators, suppliers, entrepreneurs and potentially entirely new entrants.

“The big change is that technology can increasingly provide the infrastructure,” he says. “The creator provides the idea. And I think that will make the industry much more interesting.”

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“Operators do pay, yes, but they pay whatever suits them,” they said. “In other words, we effectively pay what benefits us. All the while, the state has no means of monitoring its regulatory policies.”

In response to these issues, earlier this year the DRC Ministry of Finance outlined plans for a new gambling monitoring platform to enhance its supervision of the sector.

The DRC government is also developing a new legal framework for the gambling industry, designed to modernise existing rules and strengthen oversight of tax collection.

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Spillemyndigheden said it contributed actively to this work and sat on FATF’s gaming sector working group. The regulator confirmed that many of the indicators in the report carry relevance for operators licensed in Denmark.

FATF’s warning on illegal and offshore gambling will resonate in Denmark. Last year, Spillemyndigheden secured a court order to block 178 unlicensed gambling sites, the largest such action in the regulator’s history. 

The case highlighted how illegal operators disguise their presence through multiple site variations, a tactic the FATF report also flags as a red flag indicator.